Y l.l/2:Serial 13760
United Stales Congressional..
i f
100th Congress — 1st Session • January 6-December 22, 1987
Senate Report
No. 216
IRAN-CONTRA INVESTIGATION
APPENDIX B, VOLUME 19
DEPOSITIONS
United States Congressional Serial Set
Serial Number 13760
United States Government Printing Office
Washington : 1989
Union Calendar No. 277
100th Congress, 1st Session
S. Rept. No. 100-216 H. Rept. No. 100-433
Report of the Congressional Committees Investigating the
Iran-Contra Affair
Appendix B: Volume 19
Depositions
Daniel K. Inouye, Chairman,
Senate Select Committee
Lee H, Hamilton, Chairman,
House Select Committee
U.S. Senate Select Committee U.S. House of Representatives
On Secret Military Assistance to Iran Select Committee to Investigate
And the Nicaraguan Opposition Covert Arms Transactions with Iran
November 13, 1987. - Committed to the Committee of the Whole House
on the State of the Union and ordered to be printed.
November 17, 1987. — Ordered to be printed.
Washington : 1988
lanittd States 3enatt
SELECT COMMITTEE ON SECRET MILITARY
ASSISTANCE TO IRAN AND THE NICARAGUAN OPPOSITION
WASHINGTON, DC 20510-6480
March 1, 1988
Honorcible John C. Stennis
President pro tempore
United States Senate
Washington, D.C.
Dear Mr. President:
We have the pleasure to transmit herewith, pursuant to
Senate Resolution 23, Appendix B to the final Report of the
Senate Select Committee on Secret Military Assistance to Iran
and the Nicaraguan Opposition. We will submit such other volumes
of Appendices to the Report as are authorized and as they become
available.
Sincerely,
'j (AjL
6C-^w^ - - V
Warren B. Rudman v^^
Vice Chairman
III
U.S. HOUSE OF REPRESENTATIVES
SELECT COMMITTEE TO INVESTIGATE
COVERT ARMS TRANSACTIONS WITH IRAN
UNITED STATES CAPITOL
WASHINGTON. DC 20515
(202) 225-7902
March 1, 1988
The Honorable Jim Wright
Speaker of the House
U. S. Capitol
Washington, D. C. 20515
Dear Mr . Speaker :
Pursuant to the provisions of House Resolutions 12 and
330 and House Concurrent Resolution 195, 100th Congress, 1st
Session, I transmit herewith Appendix B to the Report of the
Congressional Committees Investigating the Iran-Contra Affair,
House Report No. 100-433, 100th Congress, 1st Session.
Appendix B consists of the depositions taken by the
Select Committees during the investigation. The contents of
Appendix B have been declassified fo^-Yelease to the public.
Lee H. Hamilton
Chairman
United States Senate
Select Committee on Secret Military Assistance
To Iran and the Nicaraguan Opposition
Daniel K. Inouye, Hawaii, Chairman
Warren Rudman, New Hampshire, Vice Chairman
George J. Mitchell, Maine
Sam Nunn, Georgia
Paul S. Sarbanes, Maryland
Howell T. Heflin, Alabama
David L. Boren, Oklahoma
James A. McClure, Idaho
Orrin G. Hatch, Utah
William S. Cohen, Maine
Paul S. Trible, Jr., Virginia
Arthur L. Liman
Chief Counsel
Mark A. Belnick Paul Barbadoro
Executive Assistant Deputy Chief Counsel
To the Chief Counsel
Mary Jane Checchi
Executive Director
Lance I. Morgan
Press Officer
VI
United States House of Representatives
Select Committee to Investigate Covert Arms
Transactions with Iran
Lee H. Hamilton, Indiana, Chairman
Dante B. Fascell, Florida, Vice Chairman
Thomas S. Foley, Washington
Peter W. Rodino, Jr., New Jersey
Jack Brooks, Texas
Louis Stokes, Ohio
Les Aspin, Wisconsin
Edward P. Boland, Massachusetts
Ed Jenkins, Georgia
Dick Cheney, Wyoming, Ranking Republican
Wm. S. Broomfield, Michigan
Henry J. Hyde, Illinois
Jim Courter, New Jersey
Bill McCollum, Florida
Michael DeWine, Ohio
John W. Nields, Jr.
Chief Counsel
W. Neil Eggleston
Deputy Chief Counsel
Kevin C. Miller
Staff Director
Thomas R. Smeeton
Minority Staff Director
George W. Van Cleve
Chief Minority Counsel
Richard J. Leon
Deputy Chief Minority Counsel
VII
United States Senate
Select Committee on Secret Military Assistance to
Iran and the Nicaraguan Opposition
Arthur L. Liman
Chief Counsel
Mark A. Belnick Paul Barbadoro
Executive Assistant Deputy Chief Counsel
to the Chief Counsel
Mary Jane Checchi
Executive Director
Lance I. Morgan
Press Officer
Associate Counsels
C. H. Albright, Jr.
Daniel Finn
C. H. Holmes
James E. Kaplan
Charles M. Kerr
Joel P. Lisker
W. T. McGough, Jr.
Richard D. Parry
John D. Saxon
Terry A. Smiljanich
Timothy C. Woodcock
Committee Staff
Assistant Counsels
Legal Counsel
Intelligence /Foreign
Policy Analysts
Investigators
Press Assistant
General Accounting
Office Detailees
Security Officer
Security Assistants
Chief Clerk
Deputy Chief Clerk
Steven D. Arkin*
Isabel K. McGinty
John R. Monsky
Victoria F. Nourse
Philip Bobbitt
Rand H. Fishbein
Thomas Polgar
Lawrence R.
Embrey, Sr.
David E. Faulkner
Henry J. Fiynn
Samuel Hirsch
John J. Cronin
Olga E. Johnson
John C. Martin
Melinda Suddes*
Robert Wagner
Louis H. Zanardi
Benjamin C.
Marshall
Georgiana
Badovinac
David Carty
Kim Lasater
Scott R. Thompson
Judith M. Keating*
Scott R. Ferguson
Staff Assistants
Administrative Staff
Secretaries
Receptionist
Computer Center
Detailee
John K. Appleby
Ruth Balin
Robert E. Esler
Ken Foster*
Martin H. Garvey
Rachel D. Kaganoff*
Craig L. Keller
Hawley K.
Manwarring
Stephen G. Miller
Jennie L. Pickford*
Michael A. Ray nor
Joseph D.
Smallwood*
Kristin K. Trenholm
Thomas E. Tremble
Bruce Vaughn
Laura J. Ison
Hilary Phillips
Winifred A. Williams*
Nancy S. Durflinger
Shari D. Jenifer
Kathryn A. Momot
Cindy Pearson
Debra S. Sheffield*
Ramona H. Green
Preston Sweet
VIII
Committee Members' Designated Liaison
Senator Inouye
Senator Rudman
Senator Mitchell
Senator Nunn
Senator Sarbanes
Senator Heflin
Peter Simons
William V. Cowan
Thomas C. Polgar
Richard H.
Arenberg
Eleanore Hill
Jeffrey H. Smith
Frederick Millhiser
Thomas J. Young
Senator Boren
Senator McClure
Senator Hatch
Senator Cohen
Senator Trible
Sven Holmes
Blythe Thomas
Jack Gerard
Dee V. Benson
James G. Phillips
James Dykstra
L. Britt Snider
Richard Cullen
Part Time*
Assistant Counsel
Hearings Coordinator
Staff Assistants
Interns
Peter V. Letsou
Joan M. Ansheles
Edward P.
Flaherty, Jr.
Barbara H. Hummell
David G. Wiencek
Nona Balaban
Edward E.
Eldridge, III
Elizabeth J. Glennie
Stephen A. Higginson
Laura T. Kunian
Julia F. Kogan
Catherine L. Udell
Document Analyst
Historian
Volunteers
Lyndal L. Shaneyfelt
Edward L. Keenan
Lewis Liman
Catherine Roe
Susan Walsh
♦The staff member was not with the Select Committee when the Report was filed but had, during
the life of the Committee, provided services.
IX
United States House of Representatives
Select Committee to Investigate
Covert Arms Transactions with Iran
Majority Staff
Special Deputy
Chief Counsel
Staff Counsels
Press Liaison
Chief Clerk
Assistant Clerk
Research Director
Research Assistants
John W. Nields, Jr.
Chief Counsel
W. Neil Eggleston
Deputy Chief Counsel
Kevin C. Miller
Staff Director
Charles Tiefer
Kenneth M. Ballen
Patrick J. Carome
V. Thomas
Fryman, Jr.
Pamela J.
Naughton
Joseph P. Saba
Robert J. Havel
Ellen P. Rayner
Debra M. Cabral
Louis Fisher
Christine C.
Birmann
Julius M.
Genachowski
Ruth D. Harvey
James E. Rosenthal
Systems
Administrator
Systems
Programmer/
Analysts
Executive Assistant
Staff Assistants
Catherine L.
Zimmer
Charles G. Ratcliff
Stephen M.
Rosenthal
Elizabeth S. Wright
Bonnie J. Brown
Christina Kalbouss
Sandra L. Koehler
Jan L. Suter
Katherine E. Urban
Kristine Willie
Mary K. Yount
Minority Staff
Associate Minority
Counsel
Assistant Minority
Counsel
Minority Research
Director
Thomas R. Smeeton
Minority Staff Director
George W. Van Cleve
Chief Minority Counsel
Richard J. Leon
Deputy Chief Minority Counsel
Robert W.
Genzman
Kenneth R. Buck
Bruce E. Fein
Minority Staff
Editor/Writer
Minority Executive
Assistant
Minority Staff
Assistant
Michael J. Malbin
Molly W. Tully
Margaret A.
Dillenburg
Committee Staff
Investigators
Director of Security
Robert A.
Bermingham
James J. Black
Thomas N.
Ciehanski
William A. Davis,
III
Clark B. Hall
Allan E. Hobron
Roger L. Kreuzer
Donald Remstein
Jack W. Taylor
Timothy E. Traylor
Bobby E. Pope
Security Officers
Editor
Deputy Editor
Associate Editor
Production Editor
Hearing Editors
Printing Clerk
Rafael Luna, Jr.
Theresa M. Martin
Milagros Martinez
Clayton C. Miller
Angel R. Torres
Joseph Foote
Lisa L. Berger
Nina Graybill
Mary J. Scroggins
David L. White
Stephen G. Regan
G. R. Beckett
Associate Staff
Representative
Hamilton
Representative
Fascell
Representative
Foley
Representative
Rodino
Representative
Brooks
Representative
Stokes
Representative
Aspin
Michael H.
Van Dusen
Christopher Kojm
R. Spencer Oliver
Bert D. Hammond
Victor Zangla
Heather S. Foley
Werner W. Brandt
M. Elaine Mielke
James J.
Schweitzer
William M. Jones
Michael J. O'Neil
Richard M. Giza
Richard E. Clark
Warren L. Nelson
Representative
Boland
Representative
Jenkins
Representative
Broomfield
Representative
Hyde
Representative
Courter
Representative
McCollum
Representative
DeWine
General Counsel to
the Clerk
Michael W. Sheehy
Robert H. Brink
Steven K. Berry
David S. Addington
Diane S. Doman
Dennis E. Teti
Tina L. Westby
Nicholas P. Wise
Steven R. Ross
XI
Contents
Volume 19
Preface XXI
Miller, Richard R 1
XIII
Depositions
Volume 1
Airline Proprietary Project Officer.
Alvarez, Francisco J.
Allen, Charles.
Arcos, Cresencio.
Volume 2
Volume 3
Armitage, Richard.
Artiano, Martin L.
Associate DDO (CIA).
Baker, James A., III.
Barbules, Lt. Gen. Peter.
Bamett, Ana.
Bartlett, Linda June.
Bastian, James H.
Brady, Nicholas F.
Brown, Arthur E., Jr.
Byrne, Phyllis M.
Calero, Adolfo.
Castillo, Tomas ("W").
Cave, George W.
C/CATF.
Volume 4
Channell, Carl R.
Chapman, John R. (With Billy Ray Reyer).
Chatham, Benjamin P.
CIA Air Branch Chief.
CIA Air Branch Deputy Chief.
CIA Air Branch Subordinate.
CIA Chief.
CIA Communicator.
CIA Identity "A".
XV
Volume 5
CIA Officer.
Clagett, C. Thomas. Jr.
Clark, Alfred (With Gregory Zink).
Clarke, George.
Clarridge. Dewey R.
Cline, Ray S.
C/NE.
Cohen, Harold G.
Volume 6
Collier, George E.
Cole, Gary.
Communications Officer Headquarters, CIA.
Conrad, Daniel L.
Volume 7
Cooper, Charles J.
Coors, Joseph.
Corbin, Joan.
Corr, Edwin G.
Coward, John C.
Coy, Craig R
Crawford, Iain T.R.
Crawford, Susan.
Crowe, Adm. William J.
Currier, Kevin W.
DCM, Country 15.
DEA Agent 1.
DEA Agent 2.
DEA Agent 3.
deGraffenreid, Kenneth,
de la Torre, Hugo.
Deputy Chief "DC".
Duemling, Robert W.
DIA Major.
Dietel, J. Edwin.
Dowling, Father Thomas.
Dutton, Robert C.
Earl, Robert.
Volume 8
Volume 9
XVI
Farber, Jacob.
Feldman, Jeffrey.
Fischer, David C.
Floor, Emanuel A.
Former CIA Officer.
Fraser, Donald.
Fraser, Edie.
Fuller, Craig L.
Volume 10
Volume 11
Furmark, Roy.
Gadd, Richard.
Gaffney, Henry.
Gaffney, Henry (With Glenn A.
Galvin, Gen. John R.
Gantt, Florence.
Garwood, Ellen Clayton.
Gast, Lt. Gen. Philip C.
Gates, Robert M.
Glanz, Anne.
Rudd).
Volume 12
George, Clair.
Godard, Ronald D.
Godson, Roy S.
Golden, William.
Gomez, Francis D.
Goodman, Adam.
Gorman, Paul F.
Graham, Daniel O.
Gregg, Donald P.
Gregorie, Richard D.
Guillen, Adriana.
Hakim, Albert.
Hall, Wilma.
Hasenfus, Eugene.
Hirtle, Jonathan J.
Hooper, Bruce.
Volume 13
Volume 14
XVII
Hunt, Nelson Bunker.
Ikle, Fred C.
Jensen, D. Lowell.
Juchniewicz, Edward
Kagan, Robert W.
Keel, Alton G.
Kellner, Leon B.
Kelly, John H.
Kiszynski, George.
Koch, Noel C.
Kuykendall, Dan H.
Langton, William G.
Lawn, John C.
Leachman, Chris J., Jr.
Ledeen, Michael A.
Lei want, David O.
Lilac, Robert H.
Lincoln, Col. James B.
Littledale, Krishna S.
McDonald, John William.
McFarlane, Robert C.
McKay, Lt. Col. John C.
McLaughlin, Jane E.
McMahon, John N.
McMahon, Stephen.
McNeil, Frank.
Makowka, Bernard.
Marostica, Don.
Marsh, John.
Mason, Robert H.
Meese, Edwin IIL
Melton, Richard H.
Merchant, Brian T.
Meo, Philip H.
Miller, Arthur J.
Miller, Henry S.
Miller, Johnathan.
Volume 15
Volume 16
Volume 17
Volume 18
XVIII
Miller, Richard R.
Motley, Langhorne A.
Mulligan, David R
Nagy, Alex G.
Napier, Shirley A.
Newington, Barbara.
North, Oliver L.
O'Boyle, William B.
Osborne, Duncan.
Owen, Robert W.
Pena, Richard.
Pickering, Thomas.
Poindexter, John M.
Posey, Thomas V.
Powell, Gen. Colin L.
Price, Charles H., II.
Proprietary Manager.
Proprietary Pilot.
Radzimski, James R.
Ramsey, John W.
Ransom, David M.
Volume 19
Volume 20
Volume 21
Volume 22
Raymond, Walter, Jr.
Regan, Donald T.
Reich, Otto J.
Revell, Oliver B.
Reyer, Billy Ray (See John Chapman).
Reynolds, William B.
Volume 23
Richard, Mark M.
Richardson, John, Jr.
Robelo, Alfonso.
Robinette, Glenn A.
Rodriguez, Felix I.
Roseman, David.
XIX
Rosenblatt, William.
Royer, Larry.
Rudd, Glenn A.
Rudd, Glenn A. (See Henry Gaffney).
Rugg, John J.
Russo, Vincent M.
Sanchez, Nestor.
Scharf, Lawrence.
Schweitzer, Robert L.
Sciaroni, Bretton G.
Secord, Richard V.
Shackley, Theodore G.
Sigur, Gaston J.
Simpson, Major C.
Sinclair, Thomas C.
Singlaub, John K.
Slease, Clyde H., IIL
Smith, Clifton.
Sofaer, Abraham D.
Steele, Col. James J.
Taft, William H., IV.
Tashiro, Jack T.
Teicher, Howard.
Thompson, Paul.
Tillman, Jacqueline.
Volume 24
Volume 25
Volume 26
Volume 27
Thurman, Gen. Maxwell.
Trott, Stephen S.
Tull, James L.
Vessey, John.
Walker, William G.
Watson, Samuel J., III.
Weinberger, Caspar.
Weld, William.
Wickham, John.
Zink, Gregory (See Alfred Clark).
XX
Preface
The House Select Committee to Investigate Covert Arms Transactions with Iran
and the Senate Select Committee on Secret Military Assistance to Iran and the
Nicaraguan Opposition, under authority contained in the resolutions establishing
them (H. Res. 12 and S. Res. 23, respectively), deposed approximately 290
individuals over the course of their 10-month joint investigation.
The use of depositions enabled the Select Committees to take sworn responses
to specific interrogatories, and thereby to obtain information under oath for the
written record and develop lines of inquiry for the public hearings.
Select Committees Members and staff counsel, including House minority
counsel, determined who would be deposed, then sought subpoenas from the
Chairmen of the Select Committees, when appropriate, to compel the individuals
to appear in nonpublic sessions for questioning under oath. Many deponents
received separate subpoenas ordering them to produce certain written documents.
Members and staff traveled throughout the United States and abroad to meet
with deponents. All depositions were stenographically reported or tape-recorded
and later transcribed and duly authenticated. Deponents had the right to review
their statements after transcription and to suggest factual and technical correc-
tions to the Select Committees.
At the depositions, deponents could assert their fifth amendment privilege
to avoid self-incrimination by refusing to answer specific questions. They were
also entitled to legal representation. Most Federal Government deponents were
represented by lawyers from their agency; the majority of private individuals
retained their own counsel.
The Select Committees, after obtaining the requisite court orders, granted
limited or "use" immunity to about 20 deponents. Such immunity means that,
while a deposed individual could no longer invoke the fifth amendment to avoid
answering a question, his or her compelled responses— or leads or collateral
evidence based on those responses— could not be used in any subsequent criminal
prosecution of that individual, except a prosecution for perjury, giving a false
statement, or otherwise failing to comply with the court order.
An executive branch Declassification Committee, located in the White House,
assisted the Committee by reviewing each page of deposition transcript and some
exhibits and identifying classified matter relating to national security. Some
depositions were not reviewed or could not be declassified for security reasons.
In addition, members of the House Select Committee staff corrected obvious
typographical errors by hand and deleted personal and proprietary information
not considered germane to the investigation.
In these Depositions volumes, some of the deposition transcripts are follow-
ed by exhibits. The exhibits— documentary evidence— were developed by Select
Committees' staff in the course of the Select Committees' investigation or were
provided by the deponent in response to a subpoena. In some cases, where the
number of exhibits was very large, the House Select Committee staff chose for
inclusion in the Depositions volumes selected documents. All of the original
XXI
exhibits are stored with the rest of the Select Committees' documents with the
National Archives and Records Administration and are available for public in-
spection subject to the respective rules of the House and Senate.
The 27 volumes of the Depositions appendix, totalling more than 30,000 pages,
consist of photocopies of declassified, hand-corrected typewritten transcripts
and declassified exhibits. Deponents appear in alphabetical order.
XXII
Publications of the Senate and House
Select Committees
Report of the Congressional Committees Investigating the Iran-Contra Affair,
1 volume, 1987.
Appendix A: Source Documents, 2 volumes, 1988.
Appendix B: Depositions, 27 volumes, 1988.
Appendix C: Chronology of Events, 1 volume, 1988.
Appendix D: Testimonial Chronology, 3 volumes, 1988.
All publications of the Select Committees are available from the U.S.
Government Printing Office.
XXIII
.1
82-724 0-88-2
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UNCUSSIF![e
SELECT COMMITTEE TO INVESTIGATE COVERT
ARMS TRANSACTIONS WITH IRAN
U.S. HOUSE OF REPRESENTATIVES
and
SELECT COMMITTEE ON SECRET MILITARY ASSISTANCE
TO IRAN AND THE NICARAGUAN OPPOSITION
UNITED STATES SENATE
Washington, D.C.
Tuesday, June 23, 1987
The deposition of RICHARD R. MILLER, called for
examination in the above-entitled matter, pursuant to notice,
in the offices of the Senate Select Committee, Room 901, Hart
Senate Office Building, Washington, D.C, convened at 2:42
p.m., before Pamela Briggle, a notary public in and for the
District of Columbia, when were present on behalf of the
parties:
UiSSlFlEO
pb2
APPEARANCES ;
Mmmm
n
On Behalf of the Select Committee on Secret Military
Assistance to Iran and Nicaraguan Opposition of the
United States Senate:
JAMES E. KAPLAN
Associate Counsel
-and-
W. THOMAS McGOUGH, JR.
Associate Counsel
Room 901
Hart Senate Office Building
Washington, D.C.
On Behalf of the Select Committee to Investigate Arms
Transactions with Iran of the U.S. House of
Representatives :
PAMELA J. NAUGHTON
Staff Counsel
-and-
KENNETH R. BUCK
Assistant Minority Counsel
H-149, United States Capitol
Washington, D.C.
On Behalf of the Witness:
EARL C. DUDLEY, JR. ESQUIRE
-and-
RONALD G. PRECUP, ESQUIRE
Nussbaum, Owen & Webster
One Thomas Circle
Washington, D.C. 20006
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UNCIASSIHDI
WITNESS
RICHARD R. MILLER
By Mr. Kaplan
By Ms . Naughton
By Mr. Kaplan
By Mr. Buck
NUMBER
Miller 1
Miller 2
Miller 3
EXAMINATION
EXHIBITS
FOR IDENTIFICATION
UNCLASSIFIE!
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PROCEEDINGS
Whereupon ,
RICHARD R. MILLER
was called for examination by counsel for the committee, and i
having been first duly sworn by the notary public, was
examined and testified as follows:
EXAMINATION
BY MR. KAPLAN:
Q Could you please state your full name for the
record?
A Richard Roderick Miller.
Q Are you testifying here today, Mr. Miller, pursuant
to grants of immunity by the Senate and the House select
committees that compel your testimony?
A I am.
MR. KAPLAN: And I'm going to mark as Exhibit 1 to
this deposition a copy of an order issued by the United
States District Court for the District of Columbia ordering
Mr. Miller to testify at proceedings by the Senate select
committee, and also providing that no testimony or other
information compelled under this order may be used against
Mr. Miller. And that's a paraphrase of the order.
Counsel for the House select committee appearing
here today has assured Mr. Miller's counsel that the House
will be forwarding a copy of the immunity and compulsion
provWont o( CO. 123M
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IINCIASM
order that the House select committee has received in
connection with Mr. Miller's testimony here today.
I ask the reporter to mark that as Miller Deposition
Exhibit No. 1
[Miller Exhibit No. 1 was
marked for identification.]
BY MR. KAPLAN:
Q Mr. Miller, did you meet with Colonel North on
November 2 0th, 19 86?
A Yes.
'"*Q '* And at whose request was that meeting set up?
A Mine.
Q And why did you request a meeting with Colonel
North?
A We had been in discussion for some time about the
need to develop a public affairs and congressional effort on
behalf of the Nicaraguan resistance, the unified Nicaraguan
opposition.
Q Were you also concerned that a contra supply
netfwork that you participated in, which we'll get into later
during your testimony, was unraveling to some extent, or
might unravel?
A I wouldn't characterize it that way. There were
events taking place in the United States that I thought made
it possible that both he and I would be drawn into a legal
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UNCLASSIFIE!
situation .
Q And are the events to which you're referring, the
disclosure of the arms sales to Iran with questions directed
at you about provision of assistance to the resistance in
Nicaragua?
A Again, I wouldn't characterize it that way. It was
more a case of a closer scrutiny of Colonel North's activities
and the dredging up by the media of previous newspaper •
accounts of his assistance through private individuals to the
resistance movement.
Q Where did that meeting take place?
A In his office in the Old Executive Office Building
and also in the corridor.
Q Was there anyone in his office when you arrived at
the OEOB?
A As I recall, I waited for some time, which was
customary in those meetings -- probably 30 minutes or so.
And he finally came out of his door and shut it behind him in
such a way that I was not able to see who was in the office.
And it was clear he was doing it so that I wouldn't know who
was in the office.
Q And did you ask him who was in the office?
A I did not.
Q And did he tell you who was in the office?
No.
ltNr.1 ASSIFIEI
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Q And then I take it you proceeded to have a conver-
sation with Colonel North in the corridor outside his office?
A He said, let me walk you to the elevator. And we
talked briefly about the establishment of the UNO public
affairs and congressional effort. And I then raised the
question of potential future legal ramifications for myself
and my firm, and then ultimately for him.
Q Did you express to him that you were concerned
about revelations that had appeared in the press relating to
closer scrutiny of his activities?
A Yes, but my grfanary departure point in the conver-
sation was about the lawsuit that had taken place in Miami
brought by the Chrioticane against several people who had by
that point been named as people supporting the Nicaraguan
movement. And my concern was that as the scrutiny of his
activities broadened, eventually several other people would
probably be drawn into it. It had notlEteerf^ismissed by a
federal judge, and therefore, anybody involved should be
ready to defend themselves in federal court.
Q And you considered yourself somewhat involved?
A I did.
Q And what was the substance of the discussion you
had with Colonel North about potential need for you for a
legal defense?
A Well, I toId^h^fn.itiM^^'lfN^"'^ *^he people involved
\m\mm
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through my activities, I expected it would cost a considerable,
amount of money, and he asked how much. And I said, I would
expect it to be at least a quarter of a million dollars, and
that doesn't even take you into account. And his response to
that was, don't worry about me. I
No, he then asked how much was in the account, and i
I said about $200,000. But I said, that doesn't even take i
care of you. And he said, don't worry about me, you keep it I
for legal costs. ;
Q And when Colonel North asked you how much was in
the account, was it your understanding that the account he
was referring to were maintained by Cayman Islands' corpora-
tions under your control? ,
A Yes .
Q And were those accounts maintained in Cayman !
Islands' financial institutions? i
A The one he would have been specifically referring
to would have been the Intel Co-Operation account at Barclay's j
Bank, although he at that time did not know it was Barclay's
BanTc. j
Q But he did know that it was the Intel Co-Operation I
account? j
A Yes . I
Q Was there anything more to that evening?
A That was aboyt .ttifi AntWqi6iffi*fc I think I left. It
mtm
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wasn't very long.
Q You went down the elevator?
A Yes.
Q Did anyone else either participate, or to your
knowledge overhear your conversation in the corridor?
A Not that I'm aware of.
Q Did Colonel North stay on the floor on which his
office was when you went down the elevator?
A I really don't recall.
Q But he didn't go out with you?
A No.
Q Did you then meet with Colonel North on the next
day, November 21, 1986?
A I did.
Q And who initiated that meeting?
A Colonel North called me, which was unusual, for a
meeting and said that--his question to me, as I recall now
was, did we finish what you needed to talk about yesterday.
And I said, no. And he said, then why don't you come over.
And I think it took several attempts to get there, and that
again wasn't unusual. Things on his schedule changed rapidly.
Q When you several attempts to get there, you're
referring to changed times in the agreed upon meeting?
A Correct.
Q Do you recall what t
Colonel North called
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you to set up this meeting?
A I don't. I recall that when I got there it was
dark and it was rainy. So I would put it some time in the
late evening.
Q The meeting took place in the late evening. And
what I was asking is whether you had any recollection as to
the time of day of Colonel North's initial phone call to you
to set up the meeting?
A As I sit here, not specifically, no.
Q What about generally? Was it morning, afternoon,
before lunch, after lunch?
A I don't have a specific recollection of when.
Q How many phone calls would you say intervened
between the initial phone call and the meeting taking place?
A It seems to me it got postponed twice. There were
two instances involving some change in time. It may have
been changed and then changed back. I'm not sure. But I
remember twice there was some change in the schedule.
Q And the meeting then occurred some time in the late
afternoon or early evening?
A Well, it was late. I was able to park on G Street.
It was dark and it was raining. So I would it probably some
time after 5:00.
Q And where did the meeting actually take place?
A I went to his office. Again, I waited briefly.
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And he came out and we exchanged greetings. I don't recall
what we specifically said, but he was in effect already
packing up. He was packing his briefcase and putting on his
coat. And he said, why don't you give me a ride and I told
him I would do that.
So we talked on the way to the car. But I suspect
only as far as the door, because it was pouring down rain, as
I recall. And we probably then didn't restart our conversa-
tion until we got in the car.
Q Did he say where he wanted you to give him a ride
to?
A He said he wanted a ride — I don't remember specifi-
cally, but it was a general area, like Dupont Circle or
something like that. I recall where I dropped him off.
Q Did you then proceed to drive him towards Dupont
Circle?
A I did.
Q And can you tell us about the substance of the
conversation that you had with Colonel North?
A I was trying to tell him that I felt that the
effort — I had previously told him I thought the effort would
be a minimum of $2.5 million, and potentially as high as $5
million if it was done correctly.
Q Now what effort are you referring to?
A Public relations and_pubJ.ic affairs and congres-
lic relations and publ^ affaii
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sional activities on behalf of UNO. And that I felt that it
had to be paid for with money that came from outside the
United States. That it should not be money raised by American
citizens, it should come from foreign donors.
And that was the substance of what I was telling
him this time, that for someone to raise that money would
make them a foreign agent. I didn't think that was a
comfortable position for people, and I thought it unlikely
they could raise that amount of money for that kind of
effort, and couldn't somebody be contacting the likes of "the
Sultan or^^^^^^^^^^^^^^^^^^or people
caliber of financial capacity.
Q What was his response to that query of yours?
A As I recall, the exchange that happened just as he
exited my car--it was a very short ride. There was almost no
one on the road. He said that — I said to him, can't somebody,
can't Shultz or somebody contact^^^^^^^Hand ask them to
put up this money? And his response was, I gave one to
Shultz already and he fupked it up.
Q And did you unSderstand what he was referring to by
that comment?
A No.
Q Did you ask him what he was referring to?
A No.
Q At some other point in_ the .c^pt^ride, did North
other point in ti
mf\ AQQ5
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indicate to you that the Attorney General had suggested that
he get legal advice.?
A As I recall sometime in that period, either the day
before that day he had told me that the Attorney General--but
I don't recall--that the Attorney General had suggested that
he get legal counsel .
Q And did he say why the Attorney General suggested
he get legal counsel?
A No.
Q Did he mention to you when the Attorney General
suggested to him that he get legal counsel?
A No.
Q Did you have an impression as to when the Attorney
General might have suggested to him that he obtain legal
counsel?
A No, not really.
Q Did he describe to you anything more about the
substance of his conversation with the Attorney General?
A No.
Q Did you ask him why the Attorney General suggested
that he get legal counsel?
A No. It wasn't that long a conversation.
Q Do you recall when Colonel North related to you
that the Attorney General suggested that he obtain legal
counsel?
«HM«'
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A Again, it's the same answer as before. I'm not-- :
it's one of those two days.
Q And by those two days you're referring to Thursday,
November 20th, 198^ or Friday the 21st?
A Thursday or Friday, right.
Q And so it would have been either in the corridor, I
take it, on Thursday, November 20th, or in the car on Friday,
November 21st? .
A I would think so, yes.
Q You recall that he related the Attorney General's i
suggestion to you in a face-to-face conversation as opposed
to over the phone?
A Yes. I
I
Q Did Colonel North say anything else to you about
Secretary of State Shultz as he was departing the car on I
i
Friday, November 21? i
I
A Yes, his last words right after he made the i
statement about the Secretary not succeeding was, he said, if I
Shultz knew that the Ayatollah was bankrolling this whole \
thing he'd had a heart attack, or a coronary — I've forgotten
which. With that, he got up and left my car.
Q Did you understand what reference he was making at
the time?
A No.
Q And I take it you didn't have an opportunity to ask
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him?
BNtmSff®
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A No, I got to think about it all weekend. ;
i
Q And did you ask him at any time subsequently to |
what he was referring? j
A Didn't have to. i
Q Where was it that you dropped Colonel North off? j
A It was an office building on the north — I'm sorry, i
the southeast side of Dupont Circle. And I think the address |
is 1800 Massachusetts.
I
Q Let the record reflect there are four buildings on |
I
the corner of 18th and Massachusetts. One of them is the |
Selgrave Club; one of them is the National Trust for Historic I
Preservation; one of them is, again another older building,
the Yeater Clinic; and one of them is a new office building,
eight stories high^ that is 1800 Massachusetts Avenue,
i
sometimes known as the National Rural Electrical Cooperative I
I
Association building. |
And I take it that your recollection is that you
dropped him off at the new office building, which is 1800
Massachusetts Avenue?
A Correct.
MR. KAPLAN: I have no further questions on those
two areas. To accommodate Ms. Naughton who's here on behalf
of the House select committee, we've covered those two areas
first, a little out of <y:d|u:«^M^jRi?pt am going to have
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questions going to some background issues and then one other
area that we'd like to put on the record today.
So I will break my questioning here and turn it
over to Ms. Naughton as to whether she has any further
questions on the events occurring on November 20th and
November 21st.
MS. NAUGHTON: Thank you very much.
EXAMINATION
BY MS. NAUGHTON:
Q Mr. Miller, you mentioned this November 20th
meeting with Oliver North, sort of in the corridor of the
OEOB. Do you recall what time of day this was?
A I'm not sure, but I think it was the afternoon.
Q When you mentioned the legal problems that may be
involved with the lawsuit and so forth and he said don't
worry about me. Did he tell you why you shouldn't worry
about him?
A No.
Q Was that his last comment that you can recall?
A Yes.
Q Did he ever indicate to you that he foresaw that he
had legal problems?
A No, he didn't indicate it but I think it was clear
to both of us at that point that he probably did have some
legal problems.
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Q Did you ever discuss with him what those were
specifically?
A Well, in specific terms the only thing we discussed '
was the lawsuit in Miami. j
Q Did Mr. North ever tell you that he had consulted
with any attorney?
A He told me--I've heard him use that phrase once, I i
think, that he had consulted with an attorney, prior to that
Friday evening. But I can't tell you where specifically or i
when specifically. i
Q But the consultation was sometime within that time?
In other words, we're not talking about two years before then? ;
A I would say it was within six months of that period |
at least.
Q Now when you saw him on November 21st outside of |
his office or as he was leaving his office, can you recall j
what your conversation was in the hallway? !
A We had already begun talking about the need to have !
a public affairs and congressional liaison operation, and the |
need for it to be staffed and the level of cost associated |
with it. It was my primary reason for seeing him on Thursday, j
and this was a subsequent discussion about the same thing. |
I
Q When he mentioned that--01iver North had said that I
I
the Attorney General suggested he get legal counsel, do you |
recall how that subject came up?
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A It was an offhand comment by him, and I don't think
it fit in real well with whatever the conversation was,
because I don't recall a conversation about the subject. It
seems to me it was an offhand comment he made.
Q Can you visualize where you were when he made that
comment?
A I can't specifically for you.
Q Did it arise in the context of your activities
involved in supporting the freedom fighters in Nicaragua?
A Again, I don't have a specific memory trigger on
the conversation. I don't--I remember it as an offhanded
comment. I don't remember it as part of a continuing
conversation.
Q Had he discussed the Attorney General with you
No.
This was his first reference to the Attorney
before?
A
Q
General?
A That I remember, yes.
MS. NAUGHTON: Thank you. I have no further
questions.
EXAMINATION
BY MR. KAPLAN:
Q One further question on this topic. Did North tell
you why he was goin^ _to^ 1^00 Magsagbysetts Avenue?
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Q And you didn't ask him? |
I
A No. I
Q Now we'll switch gears, and I'm going to go into
some background information. Are you currently employed, Mr. |
Miller? j
A I am. j
Q And where are you employed? |
i
A I'm a senior partner at International Business I
Communications. |
i
Q And for how long have you been employed there? |
A Four years almost. j
I
Q Did you work for a period of time in 1979, 1980 as |
a director of broadcast services in the Reagan for President |
campaign?
A I did. !
Q And after the 1980 election, did you work for the I
I
Reagan transition team? I
I
A I did. j
i
Q And sometime shortly thereafter, did you take a
position as special assistant to the director of public
affairs at the Department of Transportation?
A Yes .
Q And for how long were you employed in that position?
A Two months
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Q From thereafter, which I take it was around
February 1981 until February of 1983, did you serve as chief
of news and public affairs for the Agency for International
Development?
A Chief of news and media relations for one year, and
then the director of public affairs for another.
Q So I kind of got the two combined. Then did you
start International Business Communications as a sole
proprietorship in early 1984?
A Yes .
Q And did IBC become a partnership comprised of
Miller Communications and Gomez International in 1986?
A Correct.
Q And did you incorporate Miller Communications in
early 1986?
A Yes.
Q And was Gomez International, to your knowledge,
also incorporated in early 1986?
A Yes.
Q And again, to your knowledge, is Frank Gomez the
principal in Gomez International?
A Yes.
Q Was a purpose of incorporating Miller Communications
and Gomez International to restructure an ongoing business
relationship you had with Fr
ou had with r'"m'' iVlilfMl a
nd to form the
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partnership of International Business Conununications? |
A That was one of the reasons, yes. \
Q Has IBC--ancl I'm referring to International i
Business Conununications by that shorthand--since its inception]
generally engaged in media relations, strategic planning for I
public affairs, political analysis, and executive branch i
liaison? Is that a fair characterization of IBC's business? :
I
A That is a fair characterization of most of IBC's |
business. i
Q Would you like to add to that? j
i
A We've done some consulting on international trade !
I
and development as well. j
Q And in or about the spring of 1985, did IBC take on j
as a client American Conservative Trust, which was a political |
action committee that had been established by Carl R.
Channell?
A Yes. Did you say May?
Q Spring of 1985. Is that accurate?
A Yes.
Q And at some time shortly thereafter, did National
Endowment for the Preservation of Liberty, another Channell
organization, also become a client of IBC's?
A They were virtually one and the same for our
purposes .
Q So they became clients at_di3out the same time in
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the spring of 1985?
A Yes, m the spring of 1985.
[Witness and counsel conferring.]
A I think for your record, it would be important to
point out that we worked for several of the Channell organiza-
tions and it was Mr. Channell's responsibility to decide how
the work product was applied to his organization. So NEPL,
National Endowment for the Preservation of Liberty, came
along later than ACT, the American Conservative Trust.
Then there were subsequent organizations, who we
also provided work product to.
Q Let's just establish for the record that when we
refer to IBC, we're referring to International Business
Communications and when we refer to NEPL or N-E-P-L, we're
referring to the National Endowment for the Preservation of
Liberty.
A Yes.
Q Was Daniel Conrad an executive director of NEPL at
the time that NEPL became a client of yours?
A Yes .
Q At or about the same period of time, was IBC
performing a variety of public relation functions for the
Nicaraguan Development Council?
A Yes.
Q How long had IBC been engaged in those public
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relations activities?
A A little less than a year.
Q At or about that same period of time, and I am
talking about the spring of 1985, were you also dealing with
Lieutenant Colonel North on matters relating to the Nicaraguan
situation?
A We were dealing with Colonel North on matters
relating to the Nicaraguan situation and other Central
American issues .
Q In or around early April 1985 did you, Frank Gomez,
Carl Channell and Dan Conrad meet over dinner in Washington,
D.C. with John Ramsey of Wichita Falls, Texas?
A Yes.
Q Was the purpose of that dinner to solicit Mr.
Ramsey to provide monetary support to Adolfo Calero and the
Nicaraguan Development Council?
A Yes.
Q At the dinner, were certain military needs of the
resistance discussed, including small arms, ammunition, and
red eye missiles?
A I wouldn't use your characterization of needs. The
types of weapons they were using, how they were supplying ■■-
themselves, what use they were making of them, all those
things were discussed.
To the best of you
UMM
.dge, did Mr. Ramsey
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subsequently make a contribution to the Nicaraguan Development i
Council? ;
A Yes . I
Q Do you recall how much that contribution was? !
A It seems to me -- my memory is not clear on this, i
but I think it was $20,000.
Q Was it your understanding that that contribution j
was made, at least in part, as a result of the dinner that we ]
just discussed, in early April, 1985? i
A Yes .
Q In early June, 1985 or maybe it was late May, did
you receive a call from Colonel North regarding a sum of
money needed by the Nicaraguan resistance?
A I believe it was the very beginning of June.
Q Did North indicate to you that the resistance
needed $50,000?
A As I recall, he was looking immediately for
$30,000.
Q Did he say something like $30,000 would be neat or
something to that effect?
A I'm aware of what you're referring to, but that's a I
subsequent conversation. But $30,000 was the figure he was j
searching for. I
Q Did he give you the number of an account into which
any money solicited for the ne^d ih<jn_ld be deposited?
LCitea tor the ne^d ij
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A Yes. I
Q Did North indicate to you for what specific purpose
the money was needed?
A Just that it was general assistance to resistance j
offices. I
Q Did you ask for the specific purpose, beyond that? !
A I don't recall asking for it. i
Q You referring to a subsequent telephone conversation!
a moment ago. when did that conversation take place? I
I
A At a later point, he asked me to transfer money j
under my control to an account which was the same account.
In that instance, he gave me those instructions that you just 1
talked about. i
MR. KAPLAN: I'm going to ask the reporter to mark, I
as Deposition Exhibit Number 2, a copy of handwritten notes |
i
that have been provided to us by your counsel in response to j
a subpoena issued by our committee. !
[Miller Exhibit Number 2
was marked for identification.]!
BY MR. KAPLAN: j
i
Q I'd ask you to take a look at those notes. Were |
those notes prepared by you?
A Yes.
Q Is that your handwriting?
Yes.
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UNCLASSIFIE
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Q Were those notes prepared during or as a result of
a phone conversation that you had with Colonel North?
A I can't recall whether this specific note was a
result of the phone conversation or a meeting, but I wrote it |
down from information he gave me. [
Q Would this have referred to -- would these notes ;
have been taken in the context of either a phone conversation i
or meetings sometime in early June, 1985? j
A Yes. i
Q Did you call -- ' j
A I'm sorry, I have to strike that. If this is from
the period I believe it is, it's probably July. But it's the i
same information that I made use of in June. j
Q In early June. So the notes might have been |
prepared as a result of a meeting or from a conversation in
early July, but the information contained in the notes is
pretty much, if not precisely the same information that
Colonel North relayed to you in early June?
A Correct.
Q Let's stay with early June. Pursuant to Colonel
North's request in early June, did you then call John Ramsey
to ask him to contribute toward the need expressed by Colonel
North?
A I believe I called Mr. Channell first and he gave me
Mr. Ramsey's phone numbejr ^nj^ Ji,afl a&jrfra 11 Mr. Ramsey directly.
inone nujni:
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UNCIiSSIFlEi
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Q And you did then call Mr. Ramsey?
A Yes.
Q Did you give to Mr. Ramsey the account information
given to you by Colonel North?
A I did.
Q Did you later learn that Mr. Ramsey had deposited
$10,000 directly into the same account, about which you had
given him information?
A Yes.
Q That was the information about the account that you
had received from Colonel North?
A Correct.
Q Did you prepare and send a mailgram over North's
name thanking Ramsey for his contribution?
A I did.
Q Did North authorize the mailgram to be sent?
A Yes .
MR. KAPLAN: Can I ask the reporter to mark as
Exhibit 3 a copy of a mailgram again which has been provided
by your counsel pursuant to subpoena by the Sejjnate Select
Committee. i
[Miller Exhibit ilumber 3
was marked for identification.
BY MR. KAPLAN:
Q Is this the mailgrcim to which I justj| referred and
his the mailgrcim to which
iiMPi hkmm
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UNCIASSIF
r^
to which you just referred in your testimony?
A Yes .
Q Just for the record, the mailgram reads "Thank you
for the help on such short notice" over the name of Colonel
North and the mailgram is sent to Mr. John Ramsey in Wichita
Falls, Texas. Is that correct?
A Correct.
Q Do you recall whether you gave, to Colonel North, a
copy of this mailgram?
A I believe I did.
Q On or about July 9, 1985, did you participate at a
meeting at the Hay-Adams Hotel with Mr. Channell, Mr. Conrad
and Colonel North?
A Yes .
Q Was the purpose of that meeting that Mr. Channell
wanted to ensure that money that had been contributed by NEPL
contributors for the benefit of the Nicaraguan resistance
was, in fact, being used for that purpose?
A He wanted to be sure that it was being sent to the
correct place.
Q At that meeting, did Mr. Channel! ask Colonel North
where contributions for the resistance should be directed in
the future?
A Yes.
Q What did Colonel North respond?
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iL^i
A His response was to send them to IBC.
Q Had you formed, by that time, a Cayman Islands
corporation known as I.C., Inc.?
A I had.
Q Was I.e., Inc. formed for reasons unrelated to NEPL
or IBC's efforts on behalf of the Nicaraguan resistance?
A Yes.
Q Was Colonel North aware of the existence of I.e.,
Inc. before the July 9 dinner or meeting to which we just
referred?
A Yes.
Q Was the ncirae of I.C., Inc. changed in early May,
1986, to Intel Co-Operation, Inc.?
A Yes.
Q Pursuant to Colonel North's suggestion at the July
9 meeting or dinner, did NEPL begin to make payments for the
Nicaraguan resistance to IBC?
A Yes .
Q Did NEPL continue to make such payments at various
times though the fall of 1986 to IBC and to Intel Co-Opera-
tion?
A Yes.
Q Did you make various disbursements over time of
those NEPL payments to IBC, I.C., Inc., and Intel Co-Opera-
tion?
\Mussra
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L.jl^
Yes.
Q And by those NEPL payments, we're both referring to
payinerits made by NEPL to IBC or Intel Co-Operation to support
or provide assistance to the Nicaraguan resistance, is that
correct?
A Yes.
Q In almost all cases, were those disbursements made
pursuant to a direction you received from Colonel North?
A Yes.
Q Were those disbursements made to recipients or bank
accounts identified by Colonel North?
A Yes.
Q At the time that those disbursements were made, is
it fair to say that you did not ask and generally were not
told the purpose of the particular disbursements?
A Could you repeat your question?
Q Yes, I'm sorry. At the time that the disbursements
were made, that is the disbursements that were directed by
and to recipients or bank accounts identified by Colonel
North, is it fair to say that you did not ask and Colonel
North never told you what the purpose was of those disburse-
ments?
A It's not a fair characterization. It varied from
time to time. It is true that in most of the large disburse-
ments, I did not know the identify of the recipients.
uNpi mm
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UNCUSSIF
V
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Q I take it you knew the identity, but you didn't
know anything beyond the simple fact of the identity?
MR. DUDLEY: Could we go off the record for a
second?
[Discussion off the record.]
BY MR. KAPLAN:
Q Mr. Miller, just to clarify the record, it might be
helpful if you did tell us what you knew about the recipients
of money from IBC or Intel Co-Operation that was directed by
Colonel North?
A It varied by recipient. The largest portion of the
monies received by Lake Resources, we had raised for specific
activities, such, as resupply operations. But how it was
specifically sent, I can't tell you.
In the case of the some of the other large recipi-
ents, such as Alpha Services, and Mr. Calero's organizations,
my impression -- the information that I got from Colonel
North about the money transferred was very small, next to
nothing, just account information.
fT>/V
(^)
In the case of the UNO and pW/tiNO organizations, I
had a very good handle on the money that was being -- the
need for the money because it was money I was approached for,
and then there was a variety of other recipients who were
directed by — I was directed by Colonel North to send money
to, the use of which I had no idea, and they included people
UMPI Accinrp
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yNCUSSiffi
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like the Latin American Strategic Studies Institute, the
Terrorism and Subnational Conflict Institute.
I generally knew who these people were, but I
didn't have any idea of how they were spending the money.
Q Were approximately $1.7 million of IBC and I.C.,
Inc. disbursements directed by Colonel North to a Swiss bank
account held by Lake Resources?
A Yes.
Q At some point in the late fall or early winter of
1985, did Mr. Channell ask you to have North prepare and
provide a list of big ticket items needed by the Contras?
A He asked me to get from Colonel North some descrip-
tion of big ticket items that he could approach contributors
with.
Q And was there a bottom line dollar aim that these
big ticket items should add up to?
A Initially, as I recall, it was about $1.2 million.
Q Did you understand that the list was to be used by
Channell to solicit contributions for that resistance?
A
Q
A
Q
to you?
A
Yes.
Did you relay the request to Colonel North?
Yes.
Did Colonel North then orally provide such a list
He provided orally information on several items
JIMP! AdQiprn
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UNCLASSIF
33
that I then incorporated into a list.
Q Did you enter that list onto your computer at the
time?
A I did.
Q Do you recall that the list provided by Colonel
North orally included heavy lifting of cargo by aircraft?
A Yes .
Q Did the list from Colonel North also include the
training and outfitting of an urban tactics unit?
A Yes.
Q Did the list also include the resupply of the
resistance unit known as the Larry McDonald Brigade?
A I believe so.
Q Do you believe that the list provided orally by
Colonel North also included missiles of some kind?
A I believe that's true, but I don't have a copy of
the list anymore, so I can't point to it specifically, but I
did discuss specifically with Colonel North shoulder launched
surface to air missiles.
Q Did you print a copy of that list from your
computer?
A Yes.
Q Did you provide that list to Channell?
A Yes.
Did
5t from your computer?
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ULLEU KCPOimNa CO-. INC
i07 C Sirc«t. N E 2 5
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Yes.
UNCUSSIF
34
ILU
Q I take it you don't have a copy of that list today?
A I didn't retain a copy then.
Q Sometime in early November, 1985, did you par-
ticipate in a solicitation of funds from Mrs. Barbara
Newington?
A I participated in a solicitation of Barbara
Newington, yes.
Q In preparation for the solicitation, did you
prepare a file folder which contained a picture of a Soviet
HIND helicopter on one side and a picture of a shoulder held
surface to air missile on the other side?
A Yes.
Q Did you meet with Mrs. Newington, Mr. Channel 1 and
Colonel North in a suite at the Hay-Adams Hotel?
A Yes.
Q Do you recall the date of that meeting?
A I've been subsequently told that it was the --
Q November 7?
A 7, but I'm noc quite certain about it, to be honest. i
Q You recall it was in the early November time period? i
A No, I don't specifically recall the date, but I I
recall the meeting. |
Q At the meeting, did Colonel North describe to Mrs. i
Newington the threat posed to the Nicaraguan resistance by j
IIMP! Accrnrn
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HIND helicopters?
ONCUSSIFIED
35
A Yes.
Q Did North refer to the file folder that had been
prepared by you?
A Briefly.
Q Did North describe the capability of the shoulder
held surface to air missile that was in the file folder to
counteract the HIND helicopter?
A He did refer to surface to air missiles but only
generally. I don't think he specifically referred to the one
in the folder.
Q When you said before that Colonel North referred
briefly to the file folder that you had prepared, how did he
refer to it?
A I don't remember the specific conversation, but he
was describing to Mrs. Newington how the HIND helicopters had
changed the battlefield tactics of the resistance forces,
breaking them into smaller units, not allowing them to have
large collections of soldiers. I also had a copy of a New
York Times piece on the HIND helicopter, and as I remember he
used that far more prominently than he used the folder.
Q Did Mrs. Newington ask Colonel North if he knew
where to obtain surface to air missiles?
A As I recall, her specific question was, and you
know where to get these? And he said ves, we know.
3t these/ And he saidve
\\m h^MwA
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ICUSSlFiEO
Q And did Colonel North quote any prices to Mrs.
Newington?
A I don't recall.
Q Did Mr. Channel! then ask Mrs. Newington if she
would help by contributing money to the resistance?
A Are you asking me if that was -- are you asking in
proper time? Because I'm not sure whether Colonel North was
still in the room at the time.
Q I was going to ask you was Colonel North in the
room when Channell asked for a contribution?
A Colonel North, I don't think, was in the room when
Channell asked her for a specific contribution.
Q Do you know whether or not his absence from the
room at the time of Channell 's request was prearranged?
A I don't think specifically, but it was his practice
not to be in the presence of the donor when they were asked
for money.
Q Just so we clarify the record, did Channell ask Mrs.
Newington if she would contribute money for the Contras?
A Yes.
Q And did Mrs. Newington indicate whether she would
contribute?
A Yes.
Q What did she indicate?
A As I recall, I'm not sure jaihf A2>g>f I knew it
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507 C Suttt N E 25
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1202) M«-MM
37
specifically that night or subsefoeatly/ but it was
$1,200,000. " "'^ /^
Q And are you aware that Mrs. Newington- later made
stock contributions to NEPL of approximately $1 million?
A Yes. - ^ ^^
Q And^ are you aware that those coatriButions were
made sometime within the next four to six weeks?
A Yes. ^^p- ^ "~ _
-^^^^ '■-'-
Q Were those cpntributipns^^'^^sequeatly passed to IBC
.^^. .-- _ _:^ " '
and then tcfeXt^, Inc> for £uri;ea^le^Li^ia>vi.ding assistance
to the res-i*tWfce mtwement-?- --_ ^~" '" -f^-
A The9^^#ere paaaed t^ igj*JMn<f^thett"€Sey- were passed
on for the resis%emc©^ Without the report in front of me, I
can't tell you -whet her^^iJ. of it went teJueeuoh B^ ■ . Inc. or
y ha ve ~jjtop|^H*ec ^^^^jJSSf. " - Res ourcgs
passed, we^fia«*taTlld° that ^g,^^fet^^U^^6ei«r8^urned from
stock into ^ash pr^or to ^s^lng been patraed to IBC?
A I believe that's correct, by NEPI^ '~^^.
Q Wa8^_aiere aH^me after NEPL )ySg&l making payments
to IBC and_I .C .^-Inc .-aCo^ €fe Eea«t.«ft^^mbvement , that you
discussed witH^^^nel No^h your desite an?t"1rft#-<J5sire of
Frank Gomez to" receive ^compensation both for the services you
were performing and the professionj^I risk-involved in the
tunneling of funds to the resistance?
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UNCLASSIHE
A Yes.
Q When did you have that discussion with Colonel
North?
A Sometime in late '85 or very early in '86.
Q Did you tell Colonel North that you and Mr. Gomez
wanted to receive 10 percent of the NEPL payments that were
flowing through IBC or its related entities?
A That's correct.
Q And did Colonel North agree that you and Mr. Gomez
could deduct 10 percent of those payments as compensation?
A Yes.
Q And in approving that compensation, did Colonel
North indicate that he believed that 10 percent was reason- i
able? ;
A Yes.
Q Did he say that 10 percent was reasonable because i
most of the other people in the business of providing
assistance to the Contras were taking 20 to 30 percent, or
something to that effect?
A That's almost exactly what he said. !
Q Did you ultimately arrange to take 10 percent of !
the contributions that flowed through IBC and/or its related |
i
entities? j
A Yes .
Q Did you pay that amoup^ |.^f fef^poration that you
w\TOinFn^
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established in the Cayman Islands called World Affairs
Counselors, Inc.?
A Yes .
Q Did they money that went into ^rld Affairs
Counselors, Inc., that is the 10 percent, ultimately find its
way to Miller Communications and Gonea International?
A ¥es*;^ " „ -^
Q -DidT-you ever *ell Chanttellr"or~€onrad that you were
taking the fi^percent cut" from the contributions that were
flowing thro\^h.? "g^ __ '^'- _J_
-A -r did^fct telt Mr. Chemnelli, until December or
January of this^ast year." .^
MR. KAPlaN: I have no further questions under our
arrangement wittr~your"=e©un3el= to call you in on such short '
'^3uei^.^^^^pyf%xpaiarcm£ reafeey^i^^^tcg^call yo^&acK^at
soWKs later _pSthf3n~€ime, to take your testfffibny under oath
on a broader range of issues. I juBt want to state that for
the recoi?d. ^=^
rr^is~the short notice to ^u and also the Tact
that we know that you've been invoked in heavy preparation
and grand jury testimony recently, wfiFch led us ^tp f*|Bit our
examinations today and I appreciate you and-your counsel
coming down here and I apprec^te ^our cooperation in
responding t^lW
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UNWSSlFiEl)
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I don't know if House Minority Counsel has any
further questions but I'll leave the floor to him.
MR. BUCK: I'd just like to ask you a few questions,
Mr. Miller.
EXAMINATION
BY MR. BUCK:
Q Did you know Mr. North to exaggerate stories at
all? Did you find him to embellish tales?
A I've never seen any indication that he had done
that. I've seen newspaper accounts of it, but I've never had
any personal experience with him doing that.
Q Did you know that Mrs. Newington's home was
searched for bugs, for electronic eavesdropping devices, at
one time?
A Yes .
Q Did you feel that was necessary?
A It was necessary to her, so we accomplished it.
MR. BUCK: I have no further questions.
[Whereupon, at 3:44 p.m., the taking of the
deposition was concluded.]
42
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MILLf R MrO«TMO CO . MC
)07 C Sircti, N E
Wuhififion. O C 10001
41
CERTIFICATE OF NOTARY PUBLIC
I, PAMELA BRIGGLE, the officer before whom the
foregoing deposition was taken, do hereby certify that the
witness whose testimony appears in the foregoing deposition
was duly sworn by me; that the testimony of said witness was
taken by me and thereafter reduced to typewriting by me or
under my direction; that said deposition is a true record of
the testimony given by the witness; that I am neither counsel
for, related to, nor employed by any of the parties to the
action in which this deposition was taken; and further, that
I am not a relative or employee of any attorney or counsel
employed by the parties hereto, nor financially or otherwise
interested in the outcome of the action.
PAMELA BRIGGLE
Notary Public in and for t!ie
District of Columbia
My Commission expires May 14, 1990.
inr
\i\ii% siu.
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OKMI^-AL
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42 I
SELECT COMMITTEE TO INVESTIGATE COVERT
ARMS TRANSACTIONS WITH IRAN
UNITED STATES HOUSE OF REPRESENTATIVES
AND
SELECT COMMITTEE ON SECRET MILITARY ASSISTANCE
TO IRAN AND THE NICARAGUAN OPPOSITION
UNITED STATES SENATE
Friday, July 3, 1987
Washington, D.C.
The continued deposition of RICHARD R. MILLER was
commenced at 9=15 a.m., in Room 901, Hart Senate Office
Building, when were present:
For the Senate Select Committee:
THOMAS MC GOUGH, ESQ.
Associate Counsel
For the House Select Committee:
KENNETH R. BUCK, ESQ.
Assistant Minority Counsel
THOMAS FRYMAN, ESQ.
Staff Counsel
FOR THE DEPONENT:
RONALD G. PRECUP, ESQ.
ADINA N. AMITH, ESQ.
Nussbaum, Owen and Webster
1800 M Street, Northwest
Washington, D.C. 20036
^ ■ Partially Declassified/Released on Itj-eii ' ** 7
' : ' under provisions of E.G. 12356
by N. Menan, National Security Council
UNOkSSW
82-724 0044
45
inxut KcrottTwa eo.. inc.
107 C Screti. N E
Tuhiopon. D C :0002
CONTENTS
Examination by Counsel for:
House Select Committee (Mr. Buck)
Senate Select Committee (Mr. McGough)
EXHIBITS
Miller Deposition Exhibits
4
5
6
7
DMtUSSlFiED
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Page j
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4 I
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31 j
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For Identification i
4 ■
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PROCEEDINGS
(9: 15 a.m. )
MR. BUCK: Let's go on the record.
Mr. Miller, my name is Ken Buck and I am the
Assistant Minority Counsel with the House Select Conunittee,
and I'd ask everybody at the table to just introduce them-
selves, please.
MR. MC GOUGH: I'm Tom McGough, Associate Counsel
to the Senate Select Committee.
MR. FRYMAN: I'm Thomas Fryman, Staff Counsel ro
the House Committee.
MS. AMITH: I'm Adina Amith, an associate at
Nussbaum, Owen and Webster, representing Mr. Miller.
MR. FRECUP: I'm Ronald G. Precup, representing Mr.
Miller.
MR. MILLER: I'm Richard R. Miller, witness.
MR. BUCK: Mr. Miller, I'd remind you that you ' le
under oath. This is a continuation of your previous deposi-
tion.
At this time, I'd like to mark the order from the
House Select Committee, order granting immunity, as Exhibit 1
in the Miller deposition.
MR. MC GOUGH: Excuse me. If we are making this a
continuation of the other deposition, there is already a
Deposj
'"°" ^^' "' ; iijiniMSiFltD
47
UNCLASSinED
45
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MR. PRECUP: Yes. This would be number 2.
. MR. MC GOUGH: No. We ' ve got 1 , 2 , 3 . This should
be Deposition E.xhibit Number 4.
MR. PRECUP: Number 4.
[Whereupon, the document was
marked as Miller Deposition
Exhibit No. 4 for identifica-
tion. ]
Whereupon,
RICHARD R. MILLER
was recalled as a witness and, having pre'/iously been duly
sworn, was examined and testified as follows:
EXAMINATION BY COUNSEL FOR THE HOUSE SELECT COMMITTEE
BY MR. BUCK:
Q Mr. Miller, are you a partner in International
Business Communications, or IBC?
A Yes.
Q Is IBC a political and media consulting firm?
A Among other things, yes.
Q Since graduating from the University of Maryland in
1976, have you been employed in the field of broadcast
services and public affairs?
A Yes.
Q Would you say your area of expertise is public
affairs or fund-raising?
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A I would say it's public affairs and business and
trade promotion.
Q Before April 1985, how many fund-raising jobs had
you held?
A None .
Q Is it fair to say that your greatest exposure to
fund-raising a result of having Mr. Channell's corporations
as clients?
A Greatest, yes, but not only.
Q What other exposures have you had?
A I was exposed to it during the Reagan campaign and
I've had a contract with a couple of direct marketing firms.
Q Do you know if Colonel North was a fund-raiser by
profession in 1985?
A No.
Q Did Frank Gomez have fund-raising experience before
April 1985?
A Not that I'm aware of.
Q Did you know of Mr. Channell's fund-raising
experience when you met him in early 1985, or did you learn
of it soon thereafter?
A I learned about his experience in the spring of
1985.
Q Did you learn about Mr. Conrad's experience also
during that
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A Yes.
Q Did yc'j know that Mr. Channell and Mr. Conrad had
extensive experience raising funds for tax-exempt corpora-
tions?
A Yes.
Q Did you believe Mr. Channell and Mr. Conrad would
determine the legality of their fund-raising techniques?
A Yes.
Q Did you rely on Colonel North to determine the
legality of the expenditures of Lake Resources?
A Yes.
Q Did Mr. Channell discuss weapons needs of the
Nicaraguan resistance with potential contributors?
A Yes.
Q Are you aware of Mr. Channell contacting Colonel
North to tell Colonel North the specific weapons which
particular contributors donated money for?
A I don't have any direct knowledge of that.
Q Is Colonel North the type of person, in your
opinion, to buy weapons which Mr. Channell told him he should
buy? Can you answer that?
A Yes, easily. No.
Q Okay. Is it your opinion that Mr. Channell
discussed the weapons needs of the Nicaraguan resistance with
potential contributors as a fund-raising technique?
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A Yes, it's possible.
Q Were you aware that the National Endowment for the
Preservation of Liberty, or NEPL, was a 501(c)(3) tax-exempt
corporation?
A Yes.
Q When did you become aware of this?
A Probably June.
Q Of? i
A ',85.
Q Did you know that tax-exempt corporations can only
spend their money for limited purposes?
A I was generally aware of that at the time.
Q What is your understanding of those limited
purposes?
A Now, it's pretty good, but back then it was that it
simply could not be used for--my only concern was that it not
be used for things that would violate the Neutrality Act of
the United States or the Export Act, Export Control Act.
Q Did you ever tell Mr. Channell to use NEPL, as
opposed to any of his other corporations, for the purpose of
raising money for the Nicaraguan resistance?
A No.
Q Did you ever discuss with Mr. Channell the ap-
propriate Channell organization to receive money raised for
the resistance?
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A No.
Q Are you aware of Colonel North ever advising Mr.
Channell which of Mr. Channell's organizations should receive
money which was raised for the Nicaraguan resistance?
A I'm not aware of any such conversation.
Q Would Colonel North's advice on this matter be
inconsistent with the division of responsibilities, as yoa
saw those?
i
A Yes.
Q To your knowledge, was Colonel North involved in
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the day-to-day operation of any tax-exempt corporation? i
A No. !
Q Was Colonel North present when you or anybody yc^u i
know solicited money for the Nicaraguan resistance?
I
A In--let me think. Once he was present, but not in i
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immediate proximity. On another occasion, I still don't have
a clear recollection, but I believe he left the room before I
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the actual solicitation took place. |
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Q Was it Colonel North's practice to excuse himself
when potential contributors were being solicited for money on
behalf of the Nicaraguan resistance?
A Yes, and initially he refused to even be present I
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during solicitations. I
Q Do you have any knowledge that Colonel North kne
what organizations Mr. Channell or his employees were
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soliciting money for?
A I don't think he had a specific knowledge of which
organizations, but he knew Mr. Channell was president of
NEPL, National Endowment for the Preservation of Liberty.
Q Did he also know that Mr. Channell was president of
the American Conservative Trust?
A Yes -
Q Sentinel?
A Probably.
Q In other words, Mr. Channell had a great number of
corporations that he could have been raising money for, and
what I'm asking is did Colonel North know which of those
corporations he was raising money for?
A Besides the fact that I think you're extending the
universe on this, I can't — I know he knew about NEPL and I
know he knew about ACT. The others, I can't tell you because
we produced commercials that had ACT on them initially which
he had seen, and National Endowment for the Preservation of
Liberty was prevalent on the literature that he saw at the
time of summer of '85 and into '86.
Q My question is whether Colonel North knew that Mr.
Channell was raising money for a tax-exempt corporation.
A I can't speak for him in that regard.
Q Do you know specifically--.
A We have to revisit that question.
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Q Okay, let's.
A . His office, particularly--I think it was Bob Earl
requested a list of tax-exempt organizations who were on the
Administration side of the issue and one of them, as I
recall, was the American Conservative Trust. I don't think
one of them was the National Endowment for the Preservation
of Liberty.
Q Who did he request the list from?
A From Tie. He asked me to put it together, so he
would have known that the American Conservative Trust was a
501(c), whatever it was, (6) or (4), because it would have
been on the list, and you have that document somewhere.
Q Okay. You're aware that Colonel North knew that
Mr. Channell was raising money for the Nicaraguan resistance?
A Yes.
Q And you're also aware that Colonel North knew that
Mr. Channell had a few organizations, a few corporations?
A Yes.
Q Are you aware of whether Colonel North knew which
organizations Mr. Channell was using to solicit money for the
Nicaraguan resistance?
A I don't recall a specific conversation between
North and myself on which Channell entity was raising money.
Q Do you specifically know if any of the money which j
was received by International Business Communications, IC, i
'■'. -fW:
-> /r
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Inc., or Intel Cooperation, or which was distributed to other
accounts from those corporations was used to buy weapons?
A I don't know. I think the vast majority of it was
not, and I think I can prove that to some certainty.
Q But my question has to do with the time frame
within which the money was being raised. At that time, di<:l
you know of any of that money being used to buy weapons?
A At that time, we had specifically raised SI million
for weapons .
Q Thank you, and did you spend that money on weapons?
Did you personally spend that money on weapons?
A No.
Q So, to your knowledge, the money was spent--i.f ir
was spent on weapons, it was spent on weapons by someone else?
A Correct.
Q And the money was out of your control when it was
spent on weapons?
A Correct.
Q So you have no personal knowledge whether money was
ever spent on weapons, or do you have any personal knowledge?
A No.
Q Let me ask you more specifically, do you have any
knowledge of whether contributions to NEPL were used to
purchase military and other types of non-humanitarian lid for
the Contras? HllinS ft 00
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1 j A I am generally aware that money raised by NEPL was
2 ' used in the air resupply operation, which would have been a
■i
3 I military underta.king, but aside from that I don't have any--
:i
4 j| Q Could you define military undertaking for me?
5 I A There was initially an effort to deliver the 27
6 : million in humanitarian assistance to fighters deep inside
7 ;! Nicaragua, and then eventually it was a full resupply
operation.
9 Q Delivering lethal and non-lethal aid?
10 i A Correct .
11 Q Okay. I want to distinguish between a delivery of
12 I military aid and necessarily military.
13 A And the answer is no.
14 Q Okay, if you buy that distinction, if you agree
15 with that?
16 A I not only agree to it; it was exactly what was the
17 state of mind at the time. It was the way we viewed it.
18 Q That an air resupply was not a military operation?
19 A Was not military aid; it was not lethal aid. It
20 was an allowable expense.
21 Q Of?
22 A Of anybody in the United States to make. It wasn't
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24 of the Arms Export Act.
Q
Could you tell me how you developed that knowledge
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or opinion?
A My general discussion with Colonel North, discussion
with attorneys, and discussion with my partner, who was o 20-
year Foreign Service officer.
Q Did Colonel North ever show you a legal opinion
from a Washington, D.C., law firm which discussed that issue?
A No.
Q Are you aware of whether Colonel North may have had
an opinion on that subject, a legal opinion?
A Generally, but I have no specific knowledge of who
the law firm was or what the specifics of the opinion war,
but he had referenced it one time.
Q Okay. Do you know of any contributions to NEFL
which were solicited and were ultimately used to purchase
military and other types of non-humanitarian aid for the
Contras?
A Your question hinges on "ultimately used, " aside
from the air resupply effort.
Q Was it the intention of everybody involved to
purchase particular weapons with particular contributions at
the time that the money was being raised?
A Again, in the one instance in which we were
specific about weapons, it was a specific contributor,
specific amount for a specific weapon.
Q And what contribution was that?
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UNCLASSIFIED
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1 I A That was Mrs. Newington. It was roughly $1 million
2 and it was for 50 shoulder-launched. heat-seeking ground-to-
3 air missiles .
i
4 Q Are you aware of whether that money was used to
5 I purchase missiles?
6 I A No. In fact, that's the one instance in which I
I
7 ! asked Colonel North--l had seen in the paper and on tele-
8 I vision--I read everything on the subject, and did back then
9 as well, and I didn't see any evidence of an increase in the
10 number of missiles on the ground and the Hind helicopters
o -
11 were continuing to be a pretty deadly counter-f force .
y
12 And I asked him why there was not more evidence of
!
13 ] missiles and his response was they didn't need the missiles--
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they needed the radios more than they needed missiles. They
needed these more than they needed missiles, and he brought
out a brochure which was of some kind of radio, an encrypted
radio of some kind.
Q Did you meet Mr. Channell at a meeting for the
Nicaraguan refugee dinner in early 1985?
A Yes.
Q Was this the first time you met Mr. Channell?
Yes.
Did you meet Dan Conrad around the same date?
No.
When did you meet Mr. Conrad?
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A I think the first time I met Conrad was when he
came with Channe.'.l to my office.
Q Which was?
A April .
Q Of 1983?
A Right.
Q Soon after the Nicaraguan refugee dinner, did you
receive a call from John Roberts in which he told you that
Mr. Channejil wanted to help the President on Nicaragua?
A Yes.
Q Was it your impression that Mr. Channell wanted to
do a media campaign to encourage public support for a future
Congressional vote on Contra aid?
A Yes.
Q Did John Roberts indicate to you that Mr. Channell
expected you to assist Mr. Channell with fund-raising?
MR. PRECUP: Excuse me. I think you misspoke. You
used Channell twice in that sentence. Would you just repeat
the question?
MR. BUCK: Sure.
BY MR. BUCK:
Q Did John Roberts indicate to you that Mr. Channell
expected you to assist Mr. Channell with fund-raising?
A No.
Q What involvement did you have in assisting Colonel
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North or anyone else on the national security staff with
Central American issues before you received the telephone
call from John Roberts?
A As part of our State Department contract, we had
provided escort services for defectors from the Nicaraguan
government, members of the Nicaraguan opposition, internal
opposition, the senior political figures in other Central
American countries, and in doing that we had come into
contact with Colonel North.
We had also, under instructions from Jonathan
Miller, worked briefly out of North's office on securing
'^
media appearances and non\-media meetings for Adolfo Cal~5co,
J-
Arturo Cruz, and Alfonso P.ubello when they came to Washington
following their San Jose declaration.
So we knew Colonel North and he knew of our
activities prior to our relationship with Channell.
Q What did John Roberts tell you concerning Mr.
Channell when he called you the first time?
A That he used to be one of the NCPAC people, fairly
high up — I've forgotten how he exactly characterized him--
and that he wanted to do something political to help the
President, and he gave me the name of the organization and
told me that it was a federal PAC kind of like NCPAC, but
only--the difference was that Channell only took on issues
that were supportive of the President and was not publicly
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critical of the President, even though he may have differed
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with him privately. i
So his objective was to give the President political'
action support affirmatively on foreign policy issues with |
which he agreed with the President, and that was the summation;
of what Mr. Roberts told me.
Q Were there other groups or entities that were j
supporting the white House on Central American policy in j
similar ways that you were during this time frame? |
A That I was?
Q Well, that IBC was.
A Not that I'm aware of.
Q Okay.
A Not in the way IBC did, no; not as a contractor,
no. There were private groups, non|profit types, but not
corporations.
Q So there were private groups that were assisting
the White House in Central American policy?
A Several — many would be a better term.
Q Were you involved in any fund-raisdng efforts with
Colonel North or the NSC staff before you received the call
from John Roberts?
I
A No. I
Q Would it surprise you to know that John Roberts
allegedly referred to your organization as t<he White House
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outside the white House on the Central American issue?
Yes, it would surprise me.
Would that be an accurate statement?
No.
Have you known John Roberts since August 19 80?
Yes .
Would you characterize your relationship as gor'd
A
Q
A
Q
A
Q
friends?
A Yes.
Q Is your relationship with John Roberts over the
past seven years such that he may have tried to exaggerate
your importance in the Central American area to convince Mr.
Channell to use your services?
A I doubt it.
Q Okay. How many times did you hear Colonel North's
briefing on the Nicaraguan resistance in Central America?
A Twenty times, probably.
Q Was it a standard briefing or were there radical
changes in the information given out?
A It was standard.
Q Did you participate in helping Colonel North
develop that briefing program?
A I know that in the first instance of my seeing it,
some of the pictures he used were pictures Frank Gomez took
at the camps in Honduras, which was a pleasant surprise for
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us, and then much later in '86 following a Channell critique,
I suggested to Colonel North that the briefing needed to be
updated and he asked me to put together some recommendations,
which I did.
Q Who did Frank Gomez take the pictures for?
A He was in--well, for himself, but he was in the
camps as a result of our State Department contract.
Q So he then gave those pictures to the State
Department?
A He gave them to a lot of people. He just made
multiple sets and provided them to people.
Q Okay. Would it surprise you to hear that Colonel
North gave the same standard briefing to 110 different groups
during an 18-month period?
A No, not at all.
Q In the spring of 1985, did Mr. Channell ask you on
two separate occasions why he could not do more to help the
Contras?
A Yes.
Q Did it appear to you that Mr. Channell had access
to a group of potential contributors and was seeking foreign
policy issues so that he could solicit funds and retain a
percentage of the donation?
A I wouldn't characterize it that way. He was very
much interested in addressing the key foreign policy issues
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of the Reagan Adjninistration and he had settled on Nicaragua,
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terrorism, and the SDI program, and like any non-profit, he
keeps an administrative overhead. It's a part of his
operation; it's characteristic of a non4profit.
Q My question is whether Mr. Channell was attracted
to the issues and then went out and sought contributors or
did he have contributors and look for an issue with which to
seek donations?
A Oh, I think it was clear to me after the meeting in
the winter at the time of the Nicaraguan refugee fund dinner
that he had a large number of very wealthy contributors who
had a great deal of confidence in him, and that it was a
matter of him best choosing the issue to which they would
then apply their resources.
Q Did Colonel North ask you to discourage Mr.
Channell 's efforts during this time because Colonel North
could not envision Mr. Channell in that role?
A In fact, I asked him at least twice and was
declined twice for Mr. Channell to raise money directly for
the resistance.
Q And you passed this information along to Mr.
Channell?
A Well, yes, but I think I did it pretty diplomatical-
ly and I'm not sure I directly referenced Colonel North, but
I discouraged him from doing it.
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Q Did Mr. Channell proceed to invite Adolf o Calero to
speak at a fund-raising dinner?
A Yes .
Q Did Mr. Channell and Adolf o Calero discuss the
purchase of a particular type of airplane around this time
period?
A- Yes-
Q Did Mr. Channell inform you of his conversations
with Adolf,o Calero?
A Yes .
Q Did you inform Colonel North about the conversations
between Mr. Channell and Adolfo Calero?
A Yes .
Q Was Colonel North upset because the plane being
discussed had no ability to perfoirm the functions for which
it was intended?
A Yes.
Q Did Colonel North give you a peunphlet describing a
maul airplane?
A Yes.
Q Did you give this pamphlet to Mr. Channell?
A I don't recall giving him the pamphlet, but I
recall giving him the specifications of the aircraft.
Q To your knowledge, is this Colonel North's first
involvement in fund-raising activities by Mr. Channell 's
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organizations?
A . Yes.
MR. PRECUP: Do you want to just go off the record
while he's out?
MR. BUCK: Sure.
(Pause. )
MR. BUCK: Go back on the record.
BY MR. BUCK:
Q .Mr. Miller, do you know of any specific cases in
which Colonel North was present when solicitations were made
for contributions for the Nicaraguan resistance?
A He was present when solicitations were made. I'm
not entirely clear whether he left before the actual dollar
amount was discussed with the contributor.
Q Was it his general practice to leave before
solicitations were made?
A Yes.
Q Was Colonel North aware of Mr. Channell using NEPL
to solicit money for the Nicaraguan resistance?
A Again, specifically, I don't think — I don't recall
a specific conversation between myself and Colonel North that
would have indicated that he was specifically aware, but I
think generally he was aware that NEPL was the entity
Channell was using for fund-raising.
Q m early April 1985, did you, Frank Gomez, Mr.
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Channell and Mr- Conrad meet with John Ramsey?
A Yes--when did you say?
tsb' -S^^SBc^- --- ^aS»- ^ — *~ '
Q Was the purpose of the dinner to solicit funds from
Mr. Ramsey to support Adolfo Calero and the Nicaraguan
Development Council?
A That's correct.
Q Did ycu inform Colonel North that you would be
meeting Mr. Ramsey to solicit funds for Mr. Calero?
A I don't remember whether I told him or not.
Q Do you have knowledge whether Colonel North know
that Mr. Ramsey would be soliciting funds for Mr. Calero?
A I don't remember specifically.
Q Did you brief Mr. Ramsey o%n the type of weapons
that the resistance were using and how the resistance was
supplying themselves?
A In general terms, yes.
Q Who raised the subject of weapons at the Ramsey
meeting?
A Gee, I don't recall specifically who did.
Q Do you recall how the subject was raised?
A I remember that Ramsey was interested in a shotgun
drive and we told him that was not legal.
MR. MC GOUGH: I'm sorry. Not lethal or not legal?
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THE WITNESS: Legal. It was not legal, and I think
we then got into a discussion of the types of arms they were
using .
BY MR. BUCK:
Q So you believe Mr. Ramsey raised the subject first?
A That's my recollection, but, of course, we have the
transcript and we can look at that. You have it here.
Q Did you introduce Colonel North to Mr. Channell at
a briefing, on June 27th, 1985?
A I believe so, yes.
Q Was it your understanding that that was the first
time they met?
A Yes.
Q Is it fair to say that weapons were being discussed
in conjunction with raising money for the Nicaraguan resis-
tance before you introduced Colonel North to Mr. Channell?
A I'm sorry. Could you ask the question again?
Q Is it fair to say that weapons were being discussed
in conjunction with raising money for the Nicaraguan resis-
tance before you introduced Colonel North to Mr. Channell?
A Discussed by whom?
Q Discussed by yourself and Mr. Channell with Mr.
Ramsey.
A Again, in general terms, yes.
Q Previously in your deposition, you discussed a
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$10,000 contribution by John Ramsey in June of 1985?
A Well, there was a contribution. I think it's about
$10,000.
Q Okay-
A It may have been 20, but I'm not clear on the
ultimate amount.
Q I believe you also testified that in early June
1985 you received a call from Colonel North. Did he say the
resistance needed $30,000?
A Yes.
Q Did Colonel North say the resistance needed this
money because they were ill-fed, ill-equipped, ill-clothed or
lacked medicine?
A I don't recall the specific need other than
recalling that it was not for weapons. I think it was either
for political affairs or humanitarian assistance, but it was
a desperate need, nonetheless, whatever it was.
Q To your knowledge, did Mr. Ramsey's money ever pass
through a tax-exempt corporation?
A No.
Q During your conversations with Colonel North around
this time period, did you ever discuss the legality of
Colonel North requesting that you raise money for the
resistance?
A No — well, I don't specifically recall a conversation
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about it.
Q - On or about July 9th, 1985, did you participate in
a meeting at the Hay Adams Hotel with Mr. Channell, Mr.
Conrad and Colonel North?
A Yes.
Q Was there a general understanding between the four
participants in the July 9th, 1985 meeting that the money to
be raised by Channell would be used for humanitarian assis-
tance?
A I think the only supposition at that time was that
it would be used for the support of the resistance. General-
ly, during that period we were raising money for humanitarian
purposes. That was the focus of everybody, not just Channell,
involved in trying to secure funds for the resistance.
Q Do you know if Colonel North was aware of the
dinner in April in which weapons were being discussed?
A Again, I don't specifically remember a conversation
discussing it with him.
Q Did Mr. Channell request the July 9th, 1985 meeting
at the Hay Adams to ensure that money his organizations were
raising was going to the correct place?
A Yes.
Q Did Mr. Channell express a concern at that meeting
that the money he raised for a particular purpose be spent on
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A He raised the general purpose of the meeting, which
was to assure that it was going to the benefit of the
resistance .
Q Okay, but was he more specific than that?
A Not to my recollection.
Q Did anyone at this meeting discuss the organizations
Mr. Channell used to raise these funds?
A I don't recall a specific conversation on that. It
may have t^ken place, but I don't recall it.
Q Did Mr- Channell ever seek control over the use of
money after he transferred the money to your organizations?
A No.
Q Did you ever seek control over the use of money
after you transferred the money to Lake Resources or after
you transferred money anywhere else?
A No.
Q Did you form IC, Inc. so you could have a Cayman
Islands bank account?
A Yes.
Q Did IC, Inc. have two Cayman Islands bank accounts,
an interest-bearing account and a holding account?
A Ultimately, yes.
Q Was the main purpose of IC, Inc. to keep money out
of the U.S. so it would not have to _be^ taxed?
A No
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What was the main purpose of IC, Inc.?
Originally, it was set up to handle
into the United States first. It was foreign money going to i
a foreign beneficiary, and so IC, Inc. was established for
that purpose initially.
Q Was it ever the purpose of IC, Inc. to keep money
out of the U.S. so it would not have to be taxed?
A No.
Q Okay. Did you pay an annual fee to a company to
oversee the management of IC, Inc.?
A Yes .
Q Were you the sole shareholder of IC, Inc.?
A No.
Q Who else was a shareholder in IC, Inc.? |
A Francis D. Gomez and three fellow directors who are I
the managing directors in the Cayman Islands which have a
nominal number of shares.
Q Did you request the management company to change !
!
the name of IC, Inc. to Intel Cooperation in May of 1986? j
A I requested them to change it to International {
Cooperation and they got as close as they could, and under
the agreements that you have with these people they can make
those kinds of decisions and they thought Intel was close
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enough. So that's why it was called Intel as opposed to
International •
Q Was the purpose of the name change so that you
could amend the company's charter to more accurately reflect
the specific purposes for which you formed the company?
A The name was changed at the same time I amended the
charter, and the reason for amending the charter was to make
the company--the reason for amending the charter is that the
Cayman Island charters are so broad, they're not specific
enough that somebody reading them would know what a corpora-
tion does, and I wanted people to be very clear about what
the corporation did as its primary function and therefore I
amended the charter.
Q Who are the shareholders of Intel Cooperation?
A Myself, Francis D. Gomez, and I'm sorry I can't
remember who the other three are, but they are nominal
shareholders who make up the directors, managing directors in
the Cayman — .
Q The same shareholders that were shareholders of IC,
Inc. ?
A Correct. It was just a name change. It did not
change the corporate structure.
Q Before you formed IC, Inc., did you consult Colonel
North?
A Yes. I^aafl
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Q Was Colonel North ever a signatory on either of the
two Cayman Island, bank accounts?
A No.
Q Did Colonel North ever directly contact your
management company?
A No.
Q Did Colonel North have any role in the name change
or charter amendments of Intel Cooperation?
A No.
Q Is it fair to say that Colonel North did not
exercise any operational control over IC, Inc. or Intel
Cooperation?
A Operational control, no, but he did direct the
expenditures from the accounts.
Q Okay, but he asked you to direct the expenditures,
is that correct?
A He directed me to direct the expenditures .
MR. BUCK: That's all the questions I have.
MR. MC GOUGH: Can we take maybe a five-minute
break?
MR. PRECUP: Sure.
MR. MC GOUGH: I've got to take care of something,
then we'll come back.
MR. PRECUP: We're off the record.
[Brief recess . )
yNCLASSIFitO
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MR. MC GOUGH: Let's go on the record.
EXAMINATION BY COUNSEL FOR THE SENATE SELECT COMMITTEE
BY MR. MC GOUGH: i
Q Mr. Miller, there are a few questions that are
follow-ups on some of the topics we talked about in the first :
i
period and then there are some questions that follow up on ,
some of the questions that Mr. Buck asked. There are always
follow-ups to follow-ups to follow-ups. j
Just so the record is clear, does any of the j
testimony today change in any way any of the answers you gave i
during your first deposition? |
MR. PRECUP: Wait a minute. I have to object to
I
that question. It's just putting the witness at great I
disadvantage. He testified for two hours before and the '
general question, do any of these answers change anything he j
had to say before, depends upon reading the transcript. .
MR. MC GOUGH: Has he had a chance to read the |
transcript? I
MR. PRECUP: He has read the transcript, indeed he
has, but he hasn't parsed one against the other.
BY MR. MC GOUGH: |
Q Well, maybe the way to put it is, to your knowledge,]
as we sit here today is there anything in that transcript i
that's inaccurate? i
MR. PRECUP: That's a fair question.
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THE WITNESS: To my knowledge, no.
BY MR. MC GOUGH:
Q Between the time of the last deposition and this
deposition, have you met with anyone from either the House or
the Senate Committee--you personally met with anyone from
either the House or the Senate Committee?
A No.
Q And between the times of those two depositions,
were you told with any specificity what the questions were
going to be today?
A No.
Q Mr. Miller, on or about May 6th, 1987, did you
enter a plea of guilty to a one-count information in '.'ni i-p,j
States District Court?
A Yes.
MR. MC GOUGH: Let's mark it, if we could, as a
deposition exhibit.
[Whereupon, the document was
marked as Miller Deposition
Exhibit No. 5 for identifica-
tion. ]
BY MR. MC GOUGH:
Q Take a look, if you would, at what has been marked
as Deposition Exhibit 5- Is that, in fact, the information
to which you entered a plea of guilty?
immnooinrn
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A Yes.
Q And at the time you entered that plea of guilty,
did you name in open court Colonel Oliver North as a co-
conspirator?
A No.
Q Did you identify any co-conspirator in court?
A No--I'm trying to remember.
[Witness conferring with counsel.]
THE WITNESS: Well, that's a different question.
MR. MC GOUGH: What is a — .
MR. PRECUP: Would you like to go off the record?
MR. MC GOUGH: Yes, let's go off the record.
[Discussion off the record.]
MR. MC GOUGH: Let's go back on the record.
I think there was a question and the answer to the
question was no. Did he name Colonel North as a co-con-
spirator, and at that point we went off the record. If there
was an outstanding question prior to going off the record,
I'll withdraw it.
Let's have this marked as Exhibit 6, if we could.
[Whereupon, the document was
marked as Miller Deposition
Exhibit No. 6 for identifica-
tion. )
BY MR. MC GOUGH:
lilLMfiED
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Q Mr. Miller, do you recognize Exhibit 6?
A Yes.
Q And are they your notes in your handwriting?
A Yes.
Q And the date at the top, I believe, is September
18th, 1985, is that correct?
A Correct.
Q And were these notes written on or about September
18th, 1985?
A Yes.
Q Now, the numbers 7, 8 and 9 appear to be in a
slightly different script or pen than the numbers above it.
To the best of your recollection, were the numbers 7, 8 and 9
written at the same time as the numbers 1 through 6?
A No.
Q Were they written on the same day, if you know?
A I don't remember exactly.
Q Was it your practice on occasion to list numbers
consecutively even though they did not take place in the same
conversation?
A Yes.
Q Concentrating for a moment on numbers 7 and 8--
$415,000-Weapons, C4, M79; and number 8, $520,000, maul--to
the best of your recollection, what was the source of those
notes?
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A Colonel North and I had a discussion about finding
what Mr. Channell called big-ticket items for contributoL-p ,
and those were two of the items which we discussed. I don't
remember a great deal of discussion on number 7. I have a
fairly specific remembrance on number 8.
Q Now, S<il5,000 — was that an amount given to you by
Colonel North?
A I believe so.
Q And the $520,000 was also an amount given to you by
Colonel North?
A That, I'm sure of.
Q And at the time you were discussing these big-
ticket items, did you inform Colonel North that these would
be used to solicit money from contributors?
A Yes .
Q There were times, where there not, when you asked
Colonel North to draft thank you letters, and specifically
thank you letters to Mr. Channell and his organizations? Is
that fair to say?
A Yes.
Q And aunong those thank you letters were thank you
letters written commending the National Endowment for the
Preservation of Liberty and its efforts on behalf of the
Nicaraguan cause, is that correct?
A . Cause, yes.
yilASSIFI
79
iSSlFIED
Q At the briefings conducted at the white House in
which Colonel North participated--those are the briefings
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3 I sponsored by Mr- Channell--there was information distributed,
4 j was there not, on the National Endowment for the Preservation
5 j of Liberty?
6 A At the white House briefings given by Colonel
7 I North? I don't recall any.
8 Q Were there packets of information put together that j
9 were distributed at dinners or meetings after the briefings? j
10 A Yes. ]
11 Q To your knowledge, did Colonel North ever attend
12 any of those dinners or meetings?
13 A I know he attended one at the Hay Adams. I think
14 he attended one at the Hay Adams.
15 Q To your knowledge or to your recollection, did
16 Colonel North ever see any of the material or descriptive
17 material on the National Endowment for the Preservation of
18 Liberty?
19 A Probably, yes.
20 Q There were occasions, were there not, Mr. Miller,
21 where Colonel North assisted you and Mr. Channell in obtaining
22 White House support for Mr. Channell's fund-raising efforts,
23 and by that I mean either thank you letters from the President
24 to contributors or use of White House facilities or even
meetings between Mr. Channell's contributors and the Presi-
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dent? Is that fair to say?
There were times when Colonel North assisted you
and Mr. Channell in those efforts in obtaining that support
from the white House?
A Could you take them one at a time?
Q Sure.
A I mean, you've thrown out a whole bunch of ques-
tions .
Q pkay, I know I've thrown out a whole bunch. Let's
take the Presidential drop-by at the January 1986 meeting.
To your knowledge, did Colonel North assist you and Mr.
Channell in obtaining a Presidential drop-by for the January
1986 briefing?
A The answer to your question is no, specifically.
In general terms, as I understand the way the briefing was
arranged, it was arranged by the Office of Public Liaison,
who I went to in order initially to set up the briefing.
We requested that the national security briefing be
given by Colonel North and that in whatever the flow of paper
was at the White House that was agreed to. So we requested
specifically when I went to see Linda Chavez that Colonel
North would be the national security person giving the
briefing.
Q And in order to obtain Colonel North's support or
his attendance at the briefing, there were — I think you said
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there was paper flow at the White House. Is that fair to say ..
that there were memos to be written and approvals to be givon?
A I'm making an assumption that that's the case.
Q Do you ever recall drafting memoranda that described'
the National Endowment for the Preservation of Liberty or any ;
of its contributors for submission to the White House?
A I've forgotten the exact date, but in the instance ;
of Barbara Newington, we--myself, I drafted or provided some
material for the drafting of a memorandum which I believe •
originated in the State Department in the Office of Public i
Liaison to Robert McFarlan^ suggesting that Mrs. Newington be :
given an appointment with the President.
Q And in that memorandum do you recall whether you
made any mention of or described the National Endowment for r
the Preservation of Liberty? j
A I believe I did, yes, because some of the programs |
!
she had contributed to were National Endowment public
education programs.
Q Do you recall whether in these memoranda you
referred to the National Endowment for the Preservation of
Liberty as a non4profit organization?
A I don't specifically recall, but you have a copy of
the memorandum.
Q Other than Mrs. Newington 's case, can you recall
drafting for the white House's consideration any memoranda
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about the National Endowment for the Preservation of Liberty:
A I don't recall drafting any memoranda. I think we
offered potential talking points for a couple of the brief-
ings. I don't think they were used, though.
Q Those talking points, would they have referred
specifically to NEPL or would they have been more generally
on the Nicaraguan situation?
A I think they would have been on NEPL.
And would they have included the fact that NEPL was
9
a non-profit organization?
A Again, T'm not specifically sure, but, again, you
have copies of them. I don't recall specifically.
Q Colonel North had direct contact with Mr. Channell
and Mr. Conrad at times when you were not present, is that
correct?
A Correct.
Q And there came a time, did there not, when Mr.
Conrad began to bypass IBC in contacting Colonel North for
assistance or information?
A I believe that's true. I know it was at least
being attempted at one point and I had a specific conversation
with Fawn Hall about it, and my general feeling was that that
had begun to take place, yes.
Q You mentioned that Colonel North rebuffed two
attempts on behalf of Mr. Channell to raise direct support
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for the Nicaraguan cause, is that right?
A Correct.
Q Do you recall what you told Colonel North about Mr.
Channell and/or his organizations at the time you made those
proposals to him?
A Not specifically, no.
Q Do you recall whether you told him that they were
non-^-profit organizations?
Again, I don't specifically recall the conversation.
MR. MC GOUGH: Let's have this marked as Exhibit 7.
[Whereupon, the document was
marked as Miller Deposition
Exhibit No. 7 for identi t: i'-,T-
tion. ]
BY MR. MC GOUGH:
Mr. Miller, take a look at Exhibit 7, if you will.
For the record, this is copied directly out of the
Tower Commission Report, a page in the Tower Commission
Have you ever seen a chart like this before?
Yes.
Where?
In Colonel North's office.
And can you put any kind of time frame on it?
The only thing I can recall is that it was his old
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office, not the one that he was in at the time he was fired.
Q . All right, and can you just briefly tell us how
this came to your attention?
A I went to see Colonel North because I had heard
that there was going to be a public affairs effort in order
to support the Afghan resistance and I was interested in
finding out wp$ I went to try and get some business in that
regard .
i^nd I talked to him about that and his response
was, okay, well, let me show you how a covert operation is
set up, and he asked Bob Earl, as I recall, to get some kind
of a piece of paper and Earl came back in with this, only it
was on a yellow pad.
And North put it down in front of me and said, let
me show you how a covert operation is set up. And with that,
as I recall, the secure line went off in his office and he
had to take a phone call and I got to stare at this thing for
a few minutes and then I had to leave.
Q Now, to the best of your recollection, was the
chart that you saw identical to or only similar to what we've
marked as Exhibit 7?
A Similar to.
Q And in what respects, if you can recall, was it
different?
A I don't remember the number of boxes, and I
Maim urinirirn
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specifically don't remember this clutter over on the southeas-
tern quadrant .
Q All right. Now, let's go from the southeastern
quadrant to the northwestern quadrant and, in particular,
three entries there, NEPL, ACT and IBC, under the heading
■U.S. ■
Do yov recall which, if any, of those boxes was on
the chart that you saw?
A I think they were both on.
Q I think I named three, NEPL, ACT and IBC.
A I think all — .
Q All three?
A I think I remember all three being there.
Q You said that the name of IC, Inc. was changed to
Intel Cooperation, and that was done to bring it--and at the
same time the charter was changed to be more descriptive
about what the company was doing?
A Correct.
Q What was added to or modified in the charter at the
time the name was changed?
A I can try and do it from memory. I think you have
a copy of the charter. It was to make the number one charter
item the distribution of benevolent contributions to politi-
cal, benevolent and humanitarian--I 'm not sure the word
"humanitarian" was used--organizations .
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Q~ Did the charter make any; reference^ to military
#: ' . ^ ^ " -
organizations? _^ ^^^ ..;£^._.^_-;
A Not that I sgpcif icallj^fecall, rro. j_^
Q Just as you recall, political, l^nevolent and
educational organizationsij^as y6a"call it?
A That probably is accurate^^but again I'm doing it
from memory. I don' t^J5^ca^^i.t.-j^eclf icallyr^jjtalt I rernenber
political entities was one «f the words that was tfaed.
Q And which of those wit^^es would hav« been Lake
Resources? .What kind of entityfewS^' LakawResources^ "
A At the time, I^pcm^^^Si cOJHiiderea — at the time I
did that CliaLrter -chang^^ I^^ould t|^Ei[^on&ider<&d that to have
been an organization in support_of the resistance, ^t^t of
the resistance. - " .^. .#•
Q I-
It's kind qg'an wrfair qtrestiont^TomT ' If you TOuld ^how hi»
the charter page, i^ you have it wiAfe 7°^ — w»dflwi-'t have it
with-us — then. <*»;^\>^fa|»JL^^t^jna^gg!a:3f ^jdi^rfgg-an i z a t ion ,
perhaps-, tc^one^^the 'T"''^^*'^^^^—*"'^ rST''^!' ^
■^ :~-~' ^R^*» 'tr^ng'^^ "do-_^a^^rom jb^»o^' is^ it Lg. legal
lanfaa^e. ~Mr. Hillee^ no^it'l^^pr^ It is aT bit unfair to
him, I think.
BY KR. MC GOUGH:
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1 *~Q Mr. Miller, djuiyou suggest tbf language to be
2 included in the char^Bf chanjf^
3 A Yes.
4 Q And you did that, you said, I believe, to bring the
5 charter more^^taJto-lMBt with what Intel Cooperat^n w^ being
6 us«d. -^r, is that right?
7 F; - A Correct . _
Q And one o^the things Inbe^l Cooperation T»as doing
was .passing along sums of money to IiS^e Sea^urcesr^ is _that
correct? - -5 1 ^. =ji-..-~i;^ -^
A Corr^t^ -^S. ^' , "^ -r^ ~^ "
Q And Laka RM^rces, _J think you've- dessxibed as an
account--at that^time, yOu balieved^it- was aff «ccount somehow
associated wi^t what you'v« called titc resistance, is that
1^5j^corr«
f^ ^roJ^fcBj^i.^^jgJP'J^ —7* Sb chagtttefto E^IfigT^i tTf i n
its ambit an orgariTialiort asTOciated with the resistance?
-A I w^pid^have con^dered the resistance a political
-^Ri^MC GOUGffr I think that's all I have. __
-'MR^JRYHMtef Z 'ft439 ^° questions at this time. As
I indicated be fiure ~^ .j^nan , l^s^^^P^hit. this-tlaposition
will continue at another elate ,#nd I will hjjte further
questions at that^ime.
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MR. BUCK: I have no more questions.
[Whereupon, at 10:25, the taking of the deposition
was concluded.]
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CERTIFICATE OF REPORTER
I hereby certify as the stenographic reporter that
the foregoing proceedings were taken stenographically by me
and thereafter reduced to typewriting by me . I further
certify that it is a true and accurate record to the best of
my ability.
/AJnu.
Victoria A. Ranucci
iNf:USS!F!EO
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CERTIFICATE OF NOTARY PUBLIC
I, PAMELA BRIGGLE, the officer before whom the
foregoing deposition was taken, do hereby certify that the
witness whose testimony appears in the foregoing deposition
was duly sworn by me; that the testimony of said witness was
taken by me and thereafter reduced to typewriting by me or
under my direction; that said deposition is a true record of
the testimony given by the witness; that I am neither counsel
for, related to, nor employed by any of the parties to the
action in which this de[>osition was taken; and further, that
I am not a relative or employee of any attorney or counsel
employed by the parties hereto, nor financially or otherwise
interested in the outcome of the action.
PAMELA BRIGGLE
Notary Public in and for *-he
District of Columbia
My Commission expires May 14, 1990.
um
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SELECT COMMITTEE TO INVESTIGATE COVERT
ARMS TRANSACTIONS WITH IRAN
U.S. HOUSE OF REPRESENTATIVES
AND
SELECT COMMITTEE ON SECRET MILITARY ASSISTANCE
TO IRAN AND THE NICARAGUAN OPPOSITION
UNITED STATES SENATE
Thursday, August 20, 1987
Washington, D.C.
Deposition of RICHARD RODERICK MILLER taken on
behalf of the Select Committees above cited, pursuant to
notice, commencing at 9il0 a.m. in Room 901 of the Hart
Senate Office Building, before Terry Barham, a notary public
in and for the District of Columbia, when %rere present:
For the Senate Select Committee:
JAMES E. KAPLAN, Esq.
Associate Counsel
For the House Select Committee:
JOHN FRYMAN, Esq.
SPENCER OLIVER, Esq.
RICHARD J. LEON, Esq.
For the deponent:
EARL C. DUDLEY, JR., Esq.
Nussbaum, Owen & Webster
One Thomas Circle
Washington, D. C. 20005
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CONTENTS
Examination by counsel for
Paqe
Senate Select Committee
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EXHIBITS
Exhibits
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PROCEEDINGS
whereupon,
RICHARD RODERICK MILLER
assumed the witness stand and, having previously been duly
sworn, was further examined and further testified as follows:
EXAMINATION BY COUNSEL FOR
SENATE SELECT COMMITTEE
BY MR. KAPLAN:
Q Good morning, Mr. Miller.
A Good morning.
Q As you know, my name is James Kaplan, and I'm
Associate Counsel with the Senate Select Committee. This
deposition is a continuation of prior depositions which were
taken pursuant to immunity orders of both the House and
Senate Committees, which I believe are marked as Exhibit 1 —
that is the Senate Immunity Order — and Exhibit 4 — that is the
House Immunity Order, respectively.
I simply remind you that you're still under oath.
Again, Just for the record, could you state your
full name.
A Richard Roderick Miller.
And your Social Security number?
Paitially DtdmlHtd^Meaied on ^/^^ .J /^^^
And what is your date of ^ijjtj
12-22-52.
er provisions of E.0. 123S6
b)r D. SMw, NalJoiul Security Counci!
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Q Now we've gqne over your professional background, I
believe in tJife pribt depositions, except for a short period
of time. Was there a time in your career in which you formed
a public relations firm named Rand Corporation?
A RAM. R-A-M.
Q It's R-A-M7
A Right.
Q And when was that?
A Actually, it was not a corporation, it was a sole
proprietorship, and it was 1981.
Q Was that at a time when you'd been furloughed from
campaign activities on behalf of the Reagan campaign?
A That's a good choice of words. I thought of it
before. That's exactly what, had happened.
MR. DUDLEY: Off the record a minute.
MR. KAPIiAN: Sure.
[Brief discussion off the record.]
MR. KAPLAN: On the record.
BY MR. KAPLAN:
Q Off the record, in a short discussion with your
counsel, was your recollection refreshed such that you recall
that RAM Corporation, the public relations firm that you
formed, was actually formed in 1980?
A That's correct. "'..?. : , .
Q And was your recollection refreshed by the fact
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that you recalled that that corporation was formed at a time
when you had been furloughed, temporarily, from campaign
activities on behalf of the presidential campaign for Ronald
Reagan?
A Correct.
Q Could you describe your educational background for
us.
A My bachelor's degree is in government and politics
from the University of Maryland. My associate degree is in
general studies from Brandywine University. I also attended
Northeastern University, between the two of those, in Boston,
and one year prior to that at Catawba — prior to Brandywine,
at Catawba College in Wilmington — or Salisbury, North
Carolina.
Q You've testified, previously, that IBC, or Interna-
tional Business Communications became a partnership in 1986,
between Miller Communications and Gomez International. Is
that correct?
A Correct ,
Q Was there a written partnership agreement?
A No. There was not.
Q Was there a joint venture with any entity at that
time?
In July of 1986 there was a joint -venture agreement
signed between International Business Communications and
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David C. Fischer and Associates.
Q Has there ever been a written partnership agreement
between Miller Conununications and Gomez International?
A No.
Q How does the distribution of partnership proceeds
work, as between Miller Communications and Gomez Internation-
al?
A It is a 50/50 net split.
Q What is the joint-venture arrangement between IBC
and David C. Fischer and Associates?
A It was to be a 50/50 gross split on clients that we
both worked on. Shared clients.
Q Prior to July 1986, what was the structure of
International Business Communications?
A Prior to July of '86?
Q Right.
A Well, in January of 1985 — I'm sorry — January of
1986, we began operating as a partnership. We didn't form —
we formed the corporations in January, I believe.
Q Okay.
A So we were operating in '86 as a partnership.
Q As a partnership. Let's take the period, then,
prior to January 1986. What was the structure of IBC?
A It was a sole proprietorship.
Q And were you the sole proprietor?
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A Correct.
Q what was your relationship with Frank Gomez prior to
the formation of the partnership in January of '86?
A On a legal, on a legal basis, Frank was a sub-
contractor. In reality, we were working towards what was the
ultimate structure, which was a partnership.
Q And had Mr. Gomez been a subcontractor of IBC since
some time in 1984?
A Again, he was on it for legal and tax purposes, was
listed as a subcontractor, but again, we were working towards
a partnership arrangement. And in fact in '85 actually had a
split of profits, in 1985.
Q Okay. Prior to the joint-venture arrangement that
was executed as between IBC and David C. Fischer and As-
sociates in July 1986, what was the relationship between IBC
and David Fischer, if any?
A David Fischer was a subcontractor at the end of
1985 through the beginning of 1986.
Q Could you explain, for the record, what you mean
when you categorize someone as a subcontractor of IBC.
A A subcontractor, as I understand it, is somebody
who's not an employee, and is not a participant in the firm
in the way of ownership.
Q Were these people--that is, Mr. Gomez and Mr.
Fischer--acting on some sort of a consulting arrangement with
!i m^\^i\
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IBC7
A Well, again, in regards to Frank Gomez in 1985,
Frank was, for all intents and purposes?, a partner7 and: we
accomplished the change in the structure in January of '86.
As to Fischer and Marty Artiano, they were both consultants
to IBC. Senior consultants.
Q I'd like to turn your attention to IC, Inc. for a
while. When was IC, Inc. formed?
A April 1985.
Q And was IC, Inc. formed at Colonel North's request?
A Yes.
Q It was. And without going into all of the ac-
tivities involving the fake Saudi prince, who we'll get into
in much more detail later, c^n you tell us how that request
came about.
A I was approached on the telephone by a gentleman by
the name of Kevin Kattke, who told me that he had been
referred by Colonel North, and that he had a very wealthy
client who wanted to make a contribution to the Nicaraguan
resistance, and asked if I would meet him.
I called Colonel North and told him of the phone
call, and he told me that he had sent the phone call to me,
and that I should go ahead and meet with him, which I did,
and this person held himself out to be a member of the royal
Saudi family.
UNCUSSIFIEO
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And he offered $14 million in aid, which was a
rough match of what the President had asked Congress for, to
the Nicaraguan resistance, and signed, in a subsequent
meeting, a promise letter for proceeds from this oil transac-
tion. And I discussed it with Colonel North, and I told him
that I thought it would be ridiculous to bring 14 or $15
million into the United States, have the IRS promptly attach
7.5 million of it, and then have Adolf o Calero wondering
where the other 7.5 was. And since it was money coming from
Saudi Arabia and going to Calero, there was no reason for it
to come into the United States. And I suggested that the
transaction be handled offshore, and he agreed, and I--either
before or after — I'm not now sure of that conversation--
discussed it with some friends who did foreign banking, and
the best location seemed to be the Cayman Islands.
Q Who discussed that with friends?
A I did.
Q That was you?
A I did.
Q All right. Now just a moment ago, you said that it
was at Colonel North's request that you opened this Cayman
Islands account, yet, in your testimony, you suggested that
you had called Colonel North to tell him that you had come to
a conclusion that it would be better to establish this
offshore accounts, and I'm just trying to —
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A Actually, that conversation was not on the tele-
phone, it was in a meeting, and —
Q But nonetheless, what I'm trying to clarify for the
record is whose idea was it to form an offshore account to
take these funds that the Saudi prince was intending to give
to the contrast
A Well, I can't tell you exactly whose idea it was
that it be an offshore account. I can tell you that my
purpose in meeting with North was to seek his permission to
do it in the fashion that I've just described it to you.
Q Did you watch Colonel North's public testimony :-
before the Committees?
A I have no idea what — I haven't watched his tes-
timony, or John Poindexter's..
Q Are you aware that Colonel North testified that the
offshore account was established at his request?
A No . I'm not .
[Brief discussion off the record.]
MR. KAPLAN: Back on the record.
BY MR. KAPLAN:
Q Would it be inaccurate to say that the offshore
account was established at Colonel North's request?
A I don't think so. I think that's consistent with
what I've just said. I mean, I was an agent working on his
behalf. I went to ask his permission to handle it the way it
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was being handled, and the individual was sent to me at his
direction, so--
Q How did you reach the conclusion that you were an
agent working on his behalf?
A I'm not sure I really even understand the question.
Q Well, you mentioned in your previous answer, that
you considered yourself, with respect to the dealings with
the Saudi prince, to be an agent working on behalf of Colonel
North.
A Well, if you're attributing something to the word
"agent", then maybe I'll just choose another term. I was
working on his behalf.
Q Okay. And how did you arrive at the conclusion
that you were working on behalf of Colonel North?
A Well, he had sent the individual to me. I had been
involved in other activities with Colonel North, and it was
obvious that I was being asked to handle this matter.
Q And was it obvious to you that you were being asked
to handle this matter on his behalf?
A Yes.
Q what did he say to you, that led you to that
belief? Or what circumstances gave rise to that belief? If
you recall.
A First and foremost was having the individual sent
to me to begin with, since there were other avenues available
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to him.
Q What other activities had you conducted on behalf
of Colonel North, prior to the referral of the Saudi prince?
A We'd had meetings about policy in Central America.
We'd had meetings about the Nicaraguan resistance. I had
been in a couple of meetings with he and Adolf o Calero, and I
had done things such as getting the resistance leaders to
Washington for their meeting with the President. That type
of thing.
Q And these are activities that you considered to be
conducting on his behalf?
A Yes.
Q Who were the incorporators of IC, Inc.?
A Well, the two principal shareholders — and I'll
profess a slight amount of ignorance about the CayMu^n
structure--but the two principal shareholders are Francis D.
Gomez and Richard R. Miller. There are three nominal
shareholders for the purpose of — there's another legal term--
but they are in effect the voting members of the board of
directors, and they have control over the corporate structure
and the bank accounts .
Q How was Mr. Gomez chosen to be one of the principal
shareholders?
A You have to have two, and I trusted Frank, implicit-
ly-
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Q You chose Mr. Gomez?
A That's right.
MR. KAPLAN; I'll ask the reporter to mark as
Exhibit 8 a typewritten page of information relating to how
to open accounts and how to incorporate a company in the
Cayman Islands.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 8. ]
BY MR. KAPLAN:
Q Now Mr. Miller, this document, Exhibit 8, was one
of the documents that were produced to us by your counsel,
pursuant to a subpoena issued by the Committee, and I'm going
to ask you, do you recognize, this document?
A Yes.
Q And what do you recognize it as?
A It's the elements of a telephone conversation that
Frank Gomez had with somebody at the Barclays Bank.
Q Okay. Did you instruct Mr. Gomez to call the
Barclays Bank to obtain this information?
A I don't recall whether I instructed him, or he took
it on his own to do, but I had selected the Barclays Bank
after the conversations with other people.
Q Do you recall which people you had conversations
with in decidincLto choose the Barclays Bank?
CL to choose the Barclays
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A Well, I remember the conversation with the in-
dividual that led me to choose the Barclays Bank. Other
people had recommended other locations, but I'd a conversation
with Rodney Cunningham who was, at the time, the publisher of
the Rome Daily American, and the owner of two TV and radio
stations in Rome. And so he did a lot of banking overseas
and he had recommended Barclays Bank because it was an
English bank, and that was the reason it was chosen.
Q Why did you seek Mr. Cunningham's advice?
A Because I was aware of the fact that he did banking
outside the United States. I didn't know that many people
who did, and he was a good source of information.
Q How did you know Mr. Cunningham?
A I knew Mr. Cunningham from the campaign.
Q What was his position in the campaign?
A He was chairman of Citizens Abroad for Reagan, and
communications director of Republicans Abroad.
Q I think you've referred to him before as a political
friend of yours?
A Yes.
Q Did you seek any legal advice in setting up, or
establishing the corporation in the Cayman Islands?
A Well, the principal vehicle for setting up the
corporation was a law firm.
Q You testified earlier that one of the reasons why
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you chose the Cayman Islands, or decided to set up an
offshore account was so that the money, the $14 million,
wouldn't come into the United States and be taxed at half.
How did you know that the tax laws would apply to money
coming into the United States under this arrangement?
A I would say it's probably, at best, practiced —
amateur legal advice. I mean, I made the assumption that the
Internal Revenue Service would move, immediately, to attach
some portion of that money. I may have been incorrect, but I
made that assumption.
I also, for just logical reasons, don't see any
reason to bring Saudi money into the United States in order to
to somebody ^^^^^^H^^^^^^^^^^^^^H It
doesn't make any sense.
Q Was it your understanding that if the money was
transferred from Saudi Arabia to the Cayman Islands, and then
to the contras, that the money would avoid taxation? I'll
leave it at that.
MR. DUDLEY: I have a problem with the word "avoid"
in the question, Mr. Kaplan, because it seems to me that--if
you'll amend the question to say "would not be subject to
taxation. "
MR. KAPLAN: Sure. I'll take that amendment.
THE WITNESS: That's precisely the reason for doing
it in the Cayman Islands
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BY MR. KAPLAN:
Q And how did you arrive at that understanding?
A I'm not sure I understand.
Q Did you consult a lawyer to reach that conclusion?
A After I went to the Cayman Islands, I consulted
with an attorney in Washington who told me that if it was set
up the way the Cayman people were saying it was, that it
wouldn't be my responsibility to report it on a tax form.
Q Okay. Do you recall who the lawyer was that you
spoke to?
A His name is Richard Snowden. Dean Snowden, on New
Hampshire Avenue. It was free legal advice, and he did it as
a friend, and I'm sure he probably rues the day he did it.
Q Okay. I appreciate that. What was the function of
IC, Inc. before September 1985? Did it do anything?
A No.
Q Here bank accounts established in the name of IC,
Inc . 7
A There was bank accounts established. I'm sure
there was one by that time. I don't know whether--I'm sure
there was only one at that time.
Q And were the accounts established at the Barclays
Bank?
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1 Q Okay. So that the information that's contained in
2 Exhibit 8 is information that was followed?
3 A Yes .
4 Q Okay .
5 A It was recommended by the bank, and that's exactly
6 what transpired.
7 Q Did there come a time when you changed the name,
8 and the charter of IC, Inc.?
9 A Yes .
10 Q Do you recall when that was?
11 A Well, it was 1986, but I don't recall the exact
12 date. I believe it was around April.
13 Q What was the purpose in the name change?
14 A Well, IC, Inc. had only been chosen out of less than
15 inspirational thought at my conference table when this this
16 supposed Saudi prince was sitting there, and was asking for
17 the name of an organization. One had not been formed yet,
18 and I simply expected that there would not be an IC, Inc.,
19 and if there were an IC, Inc., that we'd be able to use a
20 combination of names, sufficient enough to allow us to use an
21 "a/k/a IC, Inc. . "
22 So the corporation charter request was for IC,
23 Inc., and it turns out there was no IC, Inc., so that was
24 successful. But as we began to do more work for Colonel
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felt that the organization's name and its charter should
reflect what it was doing more accurately, and so I changed
both of them.
Q Okay. And when you say that you wanted to change
the name and the charter to reflect more accurate what IC,
Inc. was doing, how did you think that a neune change was
going to reflect more accurately what IC, Inc. was doing?
A Well, both — the name, just IC, Inc., would have no
significance to anybody, and the charter was the general
Cayman Islands' charter, which is nothing but a litany of all
business practices known to man, and it's a business charter.
And so what I did was, I changed the charter,
amended the charter, which seemed to be unusual for Cayhaven's
practices and for Cayman practices, to talk about it in terms
of distributing to political and benevolent organizations,
proceeds from like organizations.
And I chose the name "International Cooperation"
because it is, I thought a little closer to what type of work
it was doing, and the only problem is that with the structure
the way it is in the Cayman Islands with these nominal
directors, they can make decisions, and there was an Interna-
tional Corporation that the Cayman Island people thought that
that "International Cooperation"" was too close.
And so our nominal directors arbitrarily decided
that Intel was close enough. And so Intel Cooperation became
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the name because Intel is a European convention for "interna-
tional." It doesn't mean that here, but it is an interna-
tional convention.
I.e.?
Did IC, Inc. stand for anything? The initials,
A No.
Q Was there any purpose as to how they were chosen?
A No.
Q Did you choose the name International Cooperation?
A Yes.
Q Did you consult with anyone in choosing that name?
A I think I informed Colonel North that I was doing
it.
Q Well, what did Colonel North say when you informed
him that you were changing the name of IC, Inc.?
A Well, I don't recall exactly what he said then, but
I recall what he said when he saw Intel Cooperation.
Q what was that?
A He said, "What the hell did you call it that for?
It sounds like intelligence." And I said well — and then I
recounted to him exactly the story that I'm recounting to you.
Q Did North show some concern that the new name might
reflect "intelligence?"
A Well, I think I just recounted the entire exchange
to you, so —
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Q Okay. Was North aware of the charter amendment
before it was made?
A I don't recall whether I told him about it before I
made it.
Q Did he become aware of the charter amendment at
some point after it was made?
A I don't know whether I told him. I don't remember
telling him. It's possible I told him and have forgotten,
but I don't remember whether I told him about the charter
change.
Q Was it your understanding at the time that the
charter was changed, that disbursements being made from IC,
Inc. were all being made to — and I'll use your words--
political and benevolent organizations?
A Yes .
Q And you didn't have any other understanding to the
contrary?
A I would only say that I had some impression that
X^ke Resources was an entity for their behalf, but never any
understanding of who they were, or what precisely it was they
were .
Q An entity for whose behalf?
A For the resistance, for the Nicaraguan resistance.
Q And did you know what the funds at that time — what
funds that were going to Calero were being used for?
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A Well, for Calero, general support, humanitarian —
food, medicine, salaries, that type of activity.
Q And that was your understanding at the time?
A Yes.
Q And did you believe that Lake Resources was a
political or benevolent organization in April 1986?
A Well, again, I thought it was some entity that was
used for the benefit of the resistance, so when I use the
word "political", I mean, were political. The Federal
Government is political. It's a political entity. It's an
organization. The resistance is an organization. It has
many different elements to it.
Q Was the name change, or charter amendment of IC,
Inc. in any way intended to .provide more secrecy to the
funneling of funds that was going on?
A No. Actually, I think it was the direct opposite.
My purpose, again, was to amend the charter to more accurately
reflect the business that the entity was doing, that IC, Inc
was doing. It didn't change, one way or the other, the
secrecy associated with that. In fact, ultimately, what I
wanted to have happen was to have funds go directly to Intel
rather than coming through IBC.
Q But you had understood that the formation of IC,
Inc., and thfe existence of this contra-funding network was
part of a covert operation, had you not?
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A Well, I want to answer your question in two parts.
We formed IC, Inc. to handle a specific transaction which did
not happen, but it was formed specifically to handle that
transaction. In a subsequent period of time, when we started
to raise money from private sources, it became the appropriate
vehicle, again, to transfer money to these political entities
Q You testified at one of the earlier sessions of
your deposition, that some time in 1985, in I believe Colonel
North's office, he sat down with you and Robert Earl, drew
out a little chart which has probably since become famous, and
in drawing out that chart with little boxes, and filling in
NEPL and IBC, and IC, Inc., and whatnot, he said something to
you to the effect of, "This is the way a real covert operation
should work. *
THE WITNESS: Wait a minute. You have 200 percent
overstated.
MR. DUDLEY: You're really inaccurate there.
THE WITNESS: Let me tell you exactly what happened
MR. KAPLAN: Well, why don't we get it accurate,
and while you're telling me what's accurate, I'm going to
pull out the earlier testimony.
THE WITNESS: Okay. I went to see Colonel North
and had a conversation with him--I believe it was about
^^^^^^^^H-but there was some word in the diplomatic
community that there was going to be some kind of a public-
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relations effort for one of the other resistance movements,
and I think it wa
And I went to hlin to talk about it, to find out who
I'd get in touch with because we wanted some IBC work in the
area. And--
MR. LEON: ; Do you have a time-frame for this, Rich?
THE WITNESS: All I remember is it was his old
office. That's the only thing I can recall. It was his old
office. So it was some time before he moved into his new
office. And I told him what I wanted to do and he said,
"Okay. Let me show you how a covert operation is set up.'
And he called Bob Earl into the room and told him
to bring some piece of paper. And when it came in, it was on
a yellow pad like a lined legal pad, but It didn't have all
the boxes that the one in the Tower Commission report has.
It wasn't quite that complicated. And he said,
"Let me show you how a covert operation is set up." I'm not
sure whether Earl was still In the room at that point, but I
was on the couch, and he set It down on the coffee table.
He no sooner got those words out of his mouth than
his secure telephone went off. He had to take a phone call on
the secure line. It proceeded for a few minutes, and then he
said "You'll have to leave," and I left, and I have never had
the chart fully explained to me.
But I remember seeing ACT, and I remember seeing
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NEPL, and I remember seeing IC, Inc. I don't think I ever
noticed INSI. I think I probably would have remembered that.
But I remember it was not as complicated as the one
I've seen in the Tower Commission report.
BY MR. KAPLAN:
Q And when you say the one you've seen in the Tower
Commission report, just for the record, that chart was marked
as Exhibit 7 at your deposition session on July 3rd.
Was IBC on the chart that Colonel North drew out?
A I believe IBC was on the chart, to tell you the
truth.
Q All right. And in terms of setting a date as to
when that chart was drawn, does it refresh your recollection
as to timing, that IC, Inc. appeared on that chart?
A Well, it's a good point. I would assxune that it was
some time after April 1985.
Q Okay.
MR. DUDLEY: I have a problem with the way that
you're using the phrase "drawn out." I mean, I think the
problem Rich is having with it is, I don't want the implica-
tion to be made that the chart was drawn in his presence, or
that he had anything to do with the drawing of the chart, and
by answering questions, that you used the phrase "drawn out."
I don't think you're intending to make that conclusion, right?
THE WITNESS: No. I was shown the piece of paper
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that already had drawing on it, and, ultimately, left without
having it fully explained to me.
BY MR. KAPLAN:
Q Nonetheless, was it your understanding that the
NEPL, IBC, IC, Inc. conduit relationship was a secret
relationship, or a part of some kind of a secret operation?
A Well, I don't agree with your characterization of
"secret", but let me tell you why.
Q Why don't you explain.
A And I think I understand what your question is,
now. Two of the things that we — the first and foremost thing,
in terms of NEPL, and the resistance, was that we wanted some
insulation between the two of them. We didn't want to have
the resistance bugging Spitz Channell for money, and we
didn't want Spitz Channell conversant with the way the money
was ultimately distributed.
And when I say "we", I say myself and Colonel North
as well. And that was just good practice not to have that
happen. Spitz had participated once before in an event that
benefited the Nicaraguan exile community, and had subsequently
been — had unsolicited requests for money.
Secondly, we were both aware that there was a great
deal of interest in our activities by the Nicaraguans and the
Cubans, and we took precautions all the tJ.me, not to be in
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open- telephone conversations, not to have organizations be
readily available for public view. So that was quite
certainly part of why we set things up the way we set them up.
Q Weren't you also concerned about exposure of your
activities in the American press?
A Of course.
Q And weren't you concerned about the exposure of
your activities to the Congress?
A No.
Q Not at all?
A I wasn't. I should say that.
Q To your knowledge, was Colonel North concerned about
the exposure of his involvement with your activities to the
Congress?
A I wouldn't want to characterize what he was feeling
at the time. The point I'd make to you is that every transac-
tion we undertook was done either through bank draft by a
meaber of the Federal Deposit System, the Federal Reserve
System. It was done by Federal
from the
proper authorities, we never — I never thought I was hiding
anything.
les , we never: — a. nevet tni
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Q The name change in 1986, were you concerned, or was
there any concern expressed^by anybotly, that by changing the
name and amending the charter in 1986, that would give rise
to more exposure to the activities- of IC, Inc.?
A No.
Q Okay. But your testimony here today is that the
charter was not eunended and the n£une was not changed for the
purpose of providing either in whole, or in part, greater
secrecy to the operation?
A I don't think it increased it or decreased it,
either way.
Q I'm asking for what the purpose was, either in
whole or in part.
A Well, ultimately, 4fhat we —
MR. DUDLEY: Is your question still limited? Was
the purpose in whole or in part to provide additional
secrecy? Is that what you're asking?
MR. KAPLAN: That's correct.
MR. DUDLEY: Okay. Why don't you answer that
question.
THE WITNESS: I don't recall it being one of the
purposes for why. I recall, most certainly, the primary
purpose, which was to have it reflect more clearly what the
organization was doing. . - - ■ '. '
MR. KAPLAN: All right. l' understand that.
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BY MR. KAPLAN:
Q Was one of the purposes either, in your mind, or to
your knowledge, in someone else's mind, to provide greater
secrecy to the operation?
A Sitting here now, I don't recall greater secrecy
being one of the reasons why I changed the charter. If I
might answer your question even more directly, the charter
change was more explicit about the type of function of the
organization than was the original charter. So, actually, I
think it has the opposite effect.
I think the charter change had the opposite effect.
Q It's your testimony here today, then, that that
charter change, that is, describing the IC, Inc. activities
as involving grants to political and benevolent organizations,
even given the knowledge that you now know, and that you now
have, was more accurate in April or May of 1986 to describe
the functions of that organization?
A Sure. More accurate than the previous charter.
Absolutely.
Q And given what you know today, is it your testimony
that a charter change to describe IC, Inc.'s activities as
being (1) to provide grants to political and benevolent
organizations, was more accurate in light of the funding that
was being made to Lake Resources, and Calero's accounts?
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A Yes.
MR. DUDLEY: I'm going to object to the form and
tone of these questions, and point out to you that one of the
problems with it is "more accurate than what?" The prior
charter contained no reference to those activities, so any
reference would technically be more accurate.
Are you suggesting there is an inaccuracy, and if
you want to suggest that, why don't you ask him, directly?
MR. KAPLAN: Well, I'd like an answer to my previous
question.
[The pending question was read by the reporter.]
MR. DUDLEY: I don't think the question is answer-
able in that form. More accurate than what?
MR. KAPLAN: More accurate than the previous
charter.
THE WITNESS: Yes, I think it was more accurate
than the previous charter.
BY MR. KAPLAN:
Q In light of what you know today, is it your
testimony that the charter amendment is an accurate descrip-
tion of the activities that were being conducted through IC,
Inc. at that time?
A Yes. You've also used my memory of the charter
change as the sole parameters of the charter change. If you
have it here, I suggest you look at it, and it's slightly
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broader than that.
Q Your memory of the charter change is fine with me.
It's what you testified to under oath here today. So your
testimony is, as you sit here today--your understanding is
that it is accurate to say that the activities of IC, Inc.
were to provide funding to political and benevolent organiza-
tions?
MR. DUDLEY: Again, Mr. Kaplan, I don't know how
many times you want to ask the question. You're obviously
not getting the answer you want.
I don't know how many times he's got to sit here
and answer it, but —
MR. KAPLAN: I haven't gotten an answer to that
question, counsel, and I'm gping to pursue it until I get an
answer to that question.
MR. DUDLEY: I'm going to finish my statement on
the record.
MR. KAPLAN: I've rephrased the question as you've
requested that I rephrase it. Now that it's been rephrased,
I'd like an answer to it. That's not difficult.
MR. DUDLEY: I would like to point out that the one
item that you have landed on is only one of several purposes
listed in the charter, and if your question is--as it can
only be--was that one of the activities that was being
carried out, because it is one of the activities that is
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described, then I'll be happy to have him answer.
MR. KAPLAN: That wasn't my question. Again, I
rephrased the question as you requested.
MR. DUDLEY: No, you didn't. Not that question.
MR. KAPLAN: Which is, is his testimony today that
the charter amendment is an accurate reflection of the
activities that IC, Inc. was conducting at the time, in light
of his knowledge today. It's not a hard question.
MR. DUDLEY: That was not —
MR. KAPLAN: It's not a difficult question to
understand, and I would like an answer to it, please, Mr.
Miller.
THE WITNESS: What was the question, again?
MR. DUDLEY; I want to get it straight because it
is a confusing and loaded question.
MR. KAPLAN: In light of your knowledge today, is
it your testimony that the activities that were being
conducted by IC, Inc. were accurately reflected by that
charter amendment that was made back in April or May of 1986?
THE WITNESS: Yes.
BY MR. KAPLAN:
Q And was funding, in light of the knowledge that you
have today, to Lake Resources, and to Calero, considered by
you to be funding to political or benevolent organizations?
A Yes.
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Q And do you have any understanding today, as to
whether Lake Resources, or Mr. Calero, or persons administer-
ing the money coining from those accounts , used those funds for
anything other than political and benevolent purposes?
A You've misread the charter change. It says it is
to give money to political and benevolent organizations.
Q And is it your understanding that Lake Resources is
a political or benevolent organization?
A Well, my understanding today is —
Q That's what I'm asking for.
A — predicated on the hearings, and I'm quite aware
that Mr. Hakim and Mr. Secord operated an organization for
the benefit of the Nicaraguan resistance, and I accept their
characterization.
Q And I mean, are you testifying that it's your
understanding, in light of the knowledge that you have today,
that Lake Resources is a political or benevolent organization?
MR. DUDLEY: That's not what he said.
THE WITNESS: I'll repeat exactly what I said, and
that is, it is my understanding, based on the testimony which
I was able to watch, that Mr. Hakim and Mr. Secord, and their
associates, operated an organization for the benefit of the
Nicaraguan resistance.
BY MR. KAPLAN:
Q And I'm asking you, and I've asked it eight times.
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and I have yet to get an answer — okay —
MR. DUDLEY: Why don't you tell him what you mean
by a "political and benevolent organization."
MR. KAPLAN: It is Mr. Miller's charter amendment
to which he testified. earlier, and I assume he has an
understanding of it. Now if he's going to answer the
question in the affirmative, then I'm going to ask him what
he means by "political or benevolent organization. "
MR. DUDLEY: Well, I consider —
MR. KAPLAN: Do you understand Lake Resources to be
a political or benevolent organization?
THE WITNESS: Now, no.
BY MR. KAPLAN:
Q Okay. And do you .understand that the activities,
then, that IC, Inc. was conducting, in funding Lake Resources-
-and I'm limiting it to that — was an activity of providing
grants to a political or benevolent organization?
A No.
Q Okay. That was easy. I think we could have done
that about 15 minutes ago.
MR. DUDLEY: I don't think we need gratuitous
comments. Why don't you ask questions, Mr. Kaplan.
MR. KAPLAN: Thank you, counsel.
BY MR. KAPLAN:
Q Is it your testimony here today, that one of the
iiMPI KQQIFIFH
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purposes of the name change, or a charter amendment to IC,
Inc., was not in whole, or in part, by you, or to your
knowledge, by anyone else, an effort to better cover the
activities of IC, Inc.?
MR. DUDLEY: That's about the twelfth time it's
been asked. Answer it once again, and this is the last time
he's going to answer it.
THE WITNESS: I don't recall that being one of the
purposes for changing the name.
MR. KAPLAN: Okay. Thank you.
I ask the reporter to mark as Exhibit 9 a handwrit-
ten document, that also was produced by your counsel in
response to the Committee's subpoenas, and ask you if you can
identify that document.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No . 9 . ]
THE WITNESS: Yes. It was a draft for a Telex to
go to David Piesing who was the administrator for our account
at Cayhaven Corporate Services in the Grand Cayman Islands.
MR. KAPLAN: Okay.
BY MR. KAPLAN:
Is that your handwriting?
Yes.
Did you prepare this draft yourself?
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A Yes.
Q Was it reviewed by anyone, do you recall?
A No.
Q And I take it that this draft confirms that you
intended to rename the corporation International Cooperation,
Inc., if you'll look on page two of the draft, toward the
middle of the page?
A Yes.
Q Okay. Was Mr. Gomez consulted?
A I'm sure I informed him of this.
Q Would he have had any input into the draft?
A I don't think so.
Q Do you recall whether Colonel North was consulted
before the draft was put int.o Telex form?
A No.
Q And would he have had any input into the preparation
of the draft?
A No. This never happened, by the way.
MR. DUDLEY: By that you mean the draft wasn't sent?
THE WITNESS: No, the draft was sent but the
actions described here did not happen.
MR. KAPLAN: Okay.
BY MR. KAPLAN:
Q I think it would be useful to clarify the record,
if you could explain a little further what you mean when you
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say that what's described in that draft, that is. Exhibit 9,
never happened.
A The counsel on the other end of this Telex, the
Walker & Company--! 'm sorry, this did happen. This is a
subsequent Telex to our initial — there's another Telex which
asks that we change the corporate structure of IC, Inc.
significantly, and place on it, in it, corporate officers,
and they refused to do that, and this was a compromise to
their position.
So that what happened was, we ended up with IC,
Inc. and a charter change, and we ended up also with world
Affairs Council.
Q Do you recall when you informed Colonel North of
that name change of Intel Cooperation, Inc.?
A I'm pretty certain it was after the fact.
Q And I take it, then, that would be the same with
respect to the charter amendment?
A I believe, also, that was after the fact.
Q Do you recall telling Colonel North about the
charter amendment, or the substance of the charter amendment?
A I don't have a specific recollection of a conversa-
tion. I do remember the exchange I told you about earlier,
about the name change, but I don't recall having — I don't
have any specific recollection of a conversation about the
charter change.
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■f
Q Okay. Let's move of^this. When did you meet
Colonel North, initially?
A Well, actually, your previous depositions refresh
my memory. Some time in 1984, and I've seen a September date
in his appointment book, so some time in the fall, I would
guess.
Q Do you recall the context in which you first met
Colonel North?
A No, but I have a very faint recollection that it
had more to do with ^^^^^^^^H than anything else.
Q And why do you believe it had to do with]
A It was at a period of time when our work for the
State Department was centered primarily on ^^^^^^^^Hand
the problems that ^^^^^^^H^ was facing.
Q Do you recall who referred you to Colonel North, or
who introduced you to hin?
A I don't have a specific recollection.
Q Do you have any recollection?
A I have an assumption, and the assumption would be
that it would have been Jonathan Miller or Ambassador Reich,
one of the people at the State Department.
Q why do you assume that it would have been either
Jonathan Miller or Reich? On what do you base that assump-
tion? I'm not trying to —
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A they would have been the only people of enough
stature to have had contact with him, that would have drawn
us into contact with him.
Q Do you recall any of the substance of that first,
or those initial meetings about ^HH^^^^^
A No; no. In fact the only two things I can recall
are a luncheon in our offices with Ambassador Reich, Jonathan
Miller, Oliver North, Frank Gomez and myself, and instances
where we went to Colonel North's office to assist with the
Washington visit of the Nicaraguan resistance leaders. Those
are the only two that I have clear recollections from that
period of time.
Q Do you recall your first dealings with Colonel
North that related to Nicara.guan, specifically?
A I don't specifically recall, no. I wouldn't know
which one to say was the first. I mean, I don't have a
specific recollection.
Q When would your first Nicaraguan-related contacts
with Colonel North have occurred? Approximately.
A Probably the winter of 1984-85.
Q And you testified earlier, I believe, that you had
done some work in coordinating or setting up a Nicaraguan
Refugee Fund dinner. Did you have dealings with Colonel
North in connection with your work setting up that dinner?
A We did not have a role setting up the dinner. We
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were observers at the dinner, on behalf of Adolfo Calero and
the Nicaraguan Development Council.
Q Did your role as observers start prior to the
dinner? I realize the dinner was postponed a couple of times.
A Yes. In fact I attended a meeting--! believe it
was in January--at the offices of Miner & Fraser, which was
supposed to be an organization meeting of all the different
groups participating, and one of the people there was Spitz
Channell .
And we reported our impression to the State
Department and to Colonel North.
Q Any other dealings with North in connection with
that dinner?
A I don't right this minute recall any others. I
mean, I saw him at the dinner. He was aware of the general
arrangements, but I don't have anything specific in memory
about it.
Q Do you recall any other dealings with Channell in
connection with your observation role for that dinner?
A No. I approached him at the meeting and introduced
myself and gave him my card, and he sort of took it very
lightly, and I got the feeling, when I left the room, I'd
never hear from him again.
Q Well, was North commonly referred to around IBC by
a code name?
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A Not--well, yes.
Q And what was that name?
A When we had telephone conversations, or when we
were conunitting something to writing, we simply wrote the
word "Green. "
Q When was the name coined?
A Some time in the summer, late summer or fall of
1985.
Q And do you recall who coined it?
A Actually, Frank Gomez coined it.
Q And why was the name Green used to refer to North?
A It was originally Frank's concern for holding open
telephone conversations, which the Channell people were — as
most civilians are — were won.t to do, and rather than using
North's name over an open telephone line, Frank suggested
that they use the name "Mr. Green Jeans" and that referred to
his fatigues, and they shortened it to Green, and it became a
convention to use Green.
Q Have you ever seen North in fatigues?
A No.
Q Had Gomez ever seen North in fatigues?
A No.
Q Did he have any reason why he would choose a name
that referred to North's fatigues?
A Well, he's a 20-year Foreign Service officer, and
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he tells me that that's done, and that when you choose a name
such as that, you do it for something that will commit it to
memory, something that's akin to the individual.
Q You said just a moment ago that Channell and his
associates would use North's name over phone lines as
civilians were wont to do, and I take it you considered
yourself and your IBC associates as civilians as well?
A Sure.
A I've had four security clearances, and in one
instance a "Q" clearance which I don't think they use
anymore.
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Q The security clearances that you've had previously,
were they in connection with positions you held within
Government?
A That's correct.
Q And those were the positions at the State Department
and AID that you testified about previously?
A And at the General Services Administration.
Q Have you ever held a security clearance outside of
the Government?
A We had a security .clearance as a contractor on our
last State Department contract.
Q And do you recall at what level that clearance was?
A I believe it was Secret.
Q Who asked that that clearance be provided?
A The State Department.
Q And any particular individual at the State Depart-
ment?
A Well, I always was under the impression, prior to
reading the report from the State Department, that Jonathan
Miller was the individual that asked for it.
Q
Has that clearance now expired?
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A For all intents and purposes, yes.
Q And has the contract pursuant to which you were
cleared expired?
A Yes.
Q And when did that expiration occur?
A September 30 of 1986.
Q When did you meet —
A May I add something?
Q Sure .
A Frank Gomez was in the Foreign Service for 20
years, and has had his assistant blown up in the room right
next to him. So that anybody that serves in foreign posts
like that has a great sensitivity to the problem of open
telephone lines, and anybody that's conversant with Washington
knows that open telephone lines here are monitored by the
Soviet complex in Cuba. There's no mystery about that.
So I'm sure when each of you took your oath and got
your security clearances, you were briefed by security
officers about that kind of activity. So, if we're dealing
in sensitive matters, it's only intelligent for us to do it
in a way that secured us enough, that it makes it difficult
for the Soviets to keep track of it.
And I suspect they'd be interested in any kind of
assistance to the Nicaraguan resistance, political or
otherwise.
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Q At IBC, do you and Frank Gomez maintain separate
offices?
A Yes.
Q Is that because of your knowledge of the history of
what's happened to some of his assistants in the past?
MR. DUDLEY: Let the record show that everybody
laughed.
MR. KAPLANS Let the record show that I very much
appreciate the laughter.
MR. LEON: I thought that was a strategic question,
John.
BY MR. KAPLAN:
Did North ever tell you anything aboutl
A Yes, and can we go off the record for a minute.
MR. KAPLAN: Sure.
[Discussion off the record.]
MR. KAPLAN: Back on the record.
MR. KAPIiANs In an of f-the-record discussion which
just occurred among counsel and Mr. Miller, in the absence of
the reporter who is not cleared, we all arrived at a consensus
conclusion, that certain information that Mr. Miller may have
to convey to the Committees might well be of a classified
nature.
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If the Committees decide to pursue the line of
questioning, which would give rise to testimony relating to
that information, we will do it at a later date and ap-
propriate time, mutually agreed upon, in which the Committees
will have secured a cleared reporter for the taking of that
deposition, or that testimony, and that testimony will be
handled pursuant to the normal security procedures of
classified information that's been employed by the Committees
since their inception.
Does anyone have anything to add or subtract from
that statement?
[No response. ]
MR. KAPLAN: All right.
BY MR. KAPLAN:
Q When did you first meet John Roberts?
A In the month of August 1980.
Q And do you recall the context in which you met him?
A Yeah. John was in charge of the editorial responses
for the Reagan-Bush campaign, and I was in charge of the
radio news service.
Q What was the substance of your relationship at that
time?
A Friends and co-workers .
Q Okay. And did you continue as friends with John
Roberts subsequent to the campaign?
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A Yes.
Q How would you describe the friendship?
A We were very good friends. We had very similar
political beliefs, and enjoyed a good friendship.
Q Did you have further professional dealings with Mr
Roberts after the campaign? That is, the 1980 campaign.
Q I had some contact with him when he was in the
political office. At the time I was in AID, and subsequent to
my leaving AID, I kept in contact with the political office,
and he was stationed in the political office.
Q What do you mean, when you refer to the "political
office?"
A There is an office of the Assistant to the President
for Political Affairs in the. Of f ice of the President.
Q Okay. So his office was in the White House?
A That ' s correct .
Q Do you recall what Mr. Roberts' position was in
early 1985?
A At some point in mid-1985 he had the title of
Deputy, I believe. If not, he was an assistant to the
director.
Q All right. And again, to clarify the record,
assistant to the director of what?
A Well, director of the Political Office, who also
carries the title of Assistant to the President for Political
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affairs.
Q Okay. When did you first meet Spitz Channell?
A I met Spitz at that meeting I recalled in January,
and then the next time I met Spitz Channell was in April of
1985. And I got a call from John Roberts who told me that he
had had two fellows come see him who wanted to help the
President on the Nicaraguan aid vote, and would I like to see
them and I said sure, I considered it a professional referral.
And I met with Mr. Channell and Mr. Conrad, along with Frank
Gomez, who provided them stacks of information which they
used to produce some series of television commercials.
And shortly thereafter, they retained IBC for
consulting.
Q When was it that you received the call from Roberts
alerting you to the fact that Channell and Conrad would be
calling on you?
A I don't recall the date, specifically, but it was in
April of '85.
Q And did you meet with Conrad and Channell some time
shortly thereafter?
A I think it was this same day or —
Q That same day?
A Or within a very short period of time. If it
wasn't the same day, it was the next day.
Q So they probably called you the same day that
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Roberts called you to alert you to the phone call —
A Actually, I think they were still with Roberts when
Roberts called.
Q Okay. The Conunittees have been told that Roberts
referred to IBC as something like the "White House outside of
the White House," or a front for the White House on Nicaragua.
A They're two very different things. I mean —
Q Were a front for the State Department on Nicaragua.
Can you respond to those characterizations?
A I don't think I want to. I mean, I never made
them. I don't accept the characterization.
Q Are you aware of any reasons why Roberts would have
characterized IBC, if in fact he did, as the "White House
outside of the White House" with respect to Nicaragua?
A I have no idea why he ' d do that .
Q Okay. And the same question with respect to the
phrase a "front for the White House with respect to Nica-
ragua?"
A Well, I think it's an affront of a characterization.
I don't agree with it.
Q But are you aware of any reasons why Roberts would
have characterized IBC that way?
A No. The only thing I would say is, I think we were
generally recognized in Washington at the time as experts on
Central American policy for the Administration, and this town
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is a very small tovm. People generally knew that we were
working with the Nicaraguan resistance also. So I don't
think that there's anything mysterious about that. I would
think somebody who was politically active, Democrat or
Republican, would have known of our interest and our expertise
in the area. We had been working with the Gulf and Caribbean
Foundation. We had been working with State Department.
We had been working with the resistance.
Q And that might explain, also, the phrase "front for
the State Department", or, "as good as the State Department"
with respect to Nicaragua.
A In the hope of not going around in an exchange
again, I really don't want to characterize it — you know — it's
his phrase. If he said it, I don't consider ourselves a
front for anybody.
Q Okay. What was your initial business relationship
with Channell and Conrad?
A Our initial business relationship started in May,
and Mr. Channell, Mr. Conrad, Frank Gomez and myself, had a
dinner at which we were offered a retainer of $15,000 a month
which we accepted, and our relationship was initially with
the American Conservative Trust.
Q what was the nature of the work that you were going
to perform for the American Conservative Trust?
A As I recall, initially, our responsibility was to
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educate Mr. Channell and his employees on the finer details
of U.S. foreign policy in Central American, and the activities
of the Nicaraguan government, and other democratic governments
in Nicaragua--or in Central America, rather. And to provide
informational materials to them which could be turned into
public-education efforts on their part.
Q And did you understand what the purpose of this
education process was to be, in so far as American Conserva-
tive Trust was concerned?
A Yes. They intended to produce campaign materials
to influence Congress, and American public opinion on the
issue of Nicaragua, in support of the President's position.
Q When you say "campaign materials", are you referring
to political campaign materials?
A Yes . ACT was a federal PAC .
Q And you said the fees were $15,000 a month. How
long did this fee arrangement hold?
A Not very long. Inside of probably — well, let me
see. By September, we were involved in other projects,
particularly those for the National Endowment for the
Preservation of Liberty, which were huge undertakings, and
our fees rose in proportion to those undertakings .
Q When did the National Endowment for the Preserva-
tion of Liberty, which we can refer to by the acronym NEPL,
become the principal Channell entity with which IBC dealt?
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A I'd say in July of 1985.
Q Of 19857
A Yes . •
Q Was there a written agreement between IBC and the
American Conservative Trust evidencing this fee arrangement?
A The initial fee arrangement, no. Subsequently, we
had budgets for proposed programs, and I think it was August,
I attempted to put it down on paper as for the understandings
between Channell and I, but I'm not sure it was captured
there, either. It was a very fluid arrangement.
Q How are the fees determined?
A They were budgeted by me, dep>ending on the work I
thought was required at IBC to accomplish what Channell was
asking be accomplished.
Q We're now talking about the fees beyond the $15,000
initial retainer?
A Even the $15,000.
Q Okay. In doing your budgeting, was there a time
basis for your fee allocation?
A You mean time and billing?
Q Yes.
A No.
Q Okay .
A We only one time, we gave to Dan Conrad a time-
and-billing analysis for a single month, which indicated
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their fees would have been $72,000 based on our hourly fees.
Q What were your hourly fees at that time?
A Partners were--I don't know. I think the chart I
gave them was $125 an hour for partners, senior staff was 75,
and I think junior staff was forty. You can see how many
hours you're talking about at that kind of level. I mean, it
doesn't take a lot of mathematics to see it was a ridiculous
workload.
Q Is it fair to say that the basis for your fees,
then, was on a transactional basis? Work done?
A Precisely, and I would budget it, I would tell
Channell what I thought it would cost to do it, and then we
would perform it for that cost.
Q Did you provide re.gular invoices to American
Conservative Trust or to NEPL?
A Not until 1986 did we really start that as a
practice, and that was at Dan Conrad's requirement.
Q All right. At the time —
A There were some. I think there was one in '85, but
most of them were in 1986.
Q Did NEPL usually pay for work performed, or did
they pay in advance for certain projects?
A They had to pay in advance for certain projects
because they were so large that we couldn't afford to--the
outlays to start them, without mjiASy-Jrom NEPL.
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Q In addition to the fees, did NEPL also reimburse
expenses, or did the fees include an allocation for expenses?
A In the program area, it required them to pay
expenses. For the general retainer, it did not require
expenses. But for program items, we did require expenses.
Q At the time that you first met Channel!, did he know
North?
A No. I should amend that. I think there was some
kind of a briefing that was associated with the Nicaraguan
Refugee Dinner, that I think maybe North gave the briefing.
You know, his slide show to that group. But I'm not positive
about that.
Q How did Channell eventually meet North, if — I mean,
beyond that group briefing? .
A At a briefing that I set up.
Q And you're referring, now, to the June 27 briefing?
A I believe that was the first one, yes.
MR. KAPLAN: This is a good time for a break.
[Brief recess. ]
BY MR. KAPLAN:
Q Mr. Miller, you testified earlier about a dinner in
early April of 1985 attended by yourself, Mr. Gomez,
Mr. Channell, Mr. Conrad, and Mr. John Ramsey from Wichita
Falls, Texas. Do you recall who arranged that dinner?
Mr. Channell.
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Q Did Channell tell you anything about Mr. Ramsey
prior to the dinner?
A That he was one of his big contributors, that — the
other thing I remember specifically is that John doesn't
believe in refugees. He feels that everybody should stand
and fight for their own country. So those are the two things
I remember as him saying.
Q Did Channell tell you anything more about Mr.
Raunsey in terms of his personality or demeanor?
A Just that he was a patriotic individual.
Q Did he describe Ramsey to you as a tough cookie or
something to that effect?
A I don't remember that specifically, but it was
clear that he was — with the refugee business, it was clear
that he was a pretty tough cookie.
Q Did you know that the discussion of — that took
place after dinner was taped?
A I may have known it at the time. I had forgotten
entirely about it until I was shown a transcript of it in
May. But after I was shown a transcript, I recalled that we
had seen a transcript of it and sent it to Mr. Conrad and
told him we didn't think it was proper for it to exist or for
it to have been done. So I get from that some sense that
maybe we were surprised that it had been done .
Q So is it your testimony that at the time of the
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dinner itself you weren't aware that that conversation was
being recorded?
A I honestly can't give you a definitive answer on
whether I was aware at the time that it was being recorded.
But I was subsequently aware that it had been recorded.
Q Do you recall the dinner?
A I recall it--I recalled it in general terms, and
now after reading the transcript, I recall it specifically.
Q And do you recall whether there was a tape recorder
on the table during the dinner?
A Again, I don't have a specific recollection of
knowing at the time that it was being recorded.
Q You testified a moment ago that you had an oppor-
tunity to review the transcript at some point in time prior
to having reviewed the transcript in connection with your
testimony before these committees. Do you recall having
reviewed the transcript in 1985 some time, for instance?
A Yes.
Q Can you describe briefly the circumstances of your
having reviewed that transcript?
A I have a very small recollection, and that was that
Frank first reviewed it for spelling and proper — Frank
Gomez — reviewed it for spelling and proper use of names and so
forth that had been transcribed by somebody who didn't know
what a Sandinista was or so forth. And then as I recall.
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when it got to me, I raised a question about why it had — why-
it even existed and why it had been done. And then it was
sent back to Dan Conrad. Or maybe we — no, it must have been
sent back to Dan.
Q With whom did you raise a question about the
propriety of the recording?
A Frank and I together — a conversation between the
two of us.
Q Did you ever express your concerns about the
recording to either Channell or Conrad?
A I'm sure we did.
Q Do you recall what their response was?
A An unschooled reaction to our concern — that they
didn't see what the problem yas.
Q Did you send the transcript back to Channell or
Conrad with some marks on it?
A I don't recall doing that, but I subsequently saw
transcript that had Frank's corrections on it — of names and
spellings and so forth.
Q And that refreshed your recollection that you in
fact probably did send back a transcript with some correc-
tions— additions or deletions — on it.
A Right. Actually, I don't think there were any
deletions. I think it was all corrections.
MR. KAPLAN: Okay. I'm going to ask the reporter
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to mark as Exhibit 10 a composite exhibit which is comprised
of a letter that we received from your counsel, Nussbaum,
Owen & Webster signed by Ron Precup dated June 16, 1987 which
encloses the transcript of that conversation as — strike
that--what it encloses is a list indicating to the best of the
indicator's recollection who spoke which paragraphs indicated
in the transcript of the conversation that occurred at that
dinner.
[The document referred to was
marked for identification as
Miller Deposition Exhibit No.
10.]
MR. MILLER: I don't want to be argumentative, but
what I did was at your request I took the transcript, and as
best I could I tried to identify the person. I will express
to you the same sense of tentativeness about that now that I
did before. I did the best I could to make a determination of
the speaker.
BY MR. KAPLAN:
Q That was going to be my first question. Is the
list that was put together and attached to Mr. Precup 's
letter — is that all from your recollection?
A Yes.
Q Did you — or to your knowledge, without disclosing
any privileged communications, anyone else--review the
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transcript in order to create this list?
A No.
Q If we can just run through the list that's attached
to the letter. The top left-hand column of the first page
says "page", and then underneath that the number 35311 — does
that refer to pagination that is on the attached transcript
itself?
A Yes.
Q Is the pagination that it refers to listed on the
bottom right-hand corner of that transcript itself?
A Yes.
Q And then the subsequent pages just relate to pages
of the transcript — also the bottom right-hand corner numbers.
A Yes.
Q I ask that because there's also a date-stamp number
in the top right-hand corner, and I wanted to make sure that
the two didn't get confused.
A Okay .
Q Now, on the right-hand column — going back to the
list provided by your counsel — it says "speaker" and then it
has initials underneath in that column. Who does "RM" refer
to?
A Myself.
Q Who does "JR" refer to?
A John Ramsey.
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Q Who does "FG" refer to?
A Frank Gomez .
Q Who does "CRC" refer to?
A Channell.
Q If you'll turn to page four of the list provided by
your counsel, you'll see about five up from the bottom in
that "speaker" column the initials "DC.
A That's Dan Conrad.
Q And then if you'll turn to page seven of that list
provided by your counsel. In the same column--the "speaker"
column--you'll see the initials "RRM". Who does that refer
to?
A Me.
Q So I take it then you referred to both with the
initials "RM" at the beginning of the list provided, and it
looks as if it's uniformly "RRM" toward the end of the list.
A Correct .
Q Did there come a time in April of 1985 when you
assisted Mr. Channell in obtaining a letter from Mr. Calero
which authorized the Channell organizations to fundraise on
behalf of FDN?
A Yes.
MR. KAPLAN: I would ask the reporter to mark as
Exhibit 11 the document which purports to be a letter from
Mr. Calero to Mr. Channell dated April 10, 1985.
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_ I [The document referred to was
2 marked for identification as
3 Miller Deposition Exhibit No.
4 11.]
5 BY MR. KAPLAN:
6 Q I ask you if you have seen that letter before.
7 A Yes .
8 Q Is this the letter? This letter was produced by
9 your counsel in response to the committees' subpoenas. Is
10 this the letter that you assisted Mr. Channell in obtaining
11 from Mr. Calero?
12 A Yes.
13 Q Do recall what the nature of your assistance was in
14 obtaining this letter?
15 A I spoke to Mr. Calero about it and asked him to
16 provide a letter. Initially a copy of the letter was given
17 to me by Mr. Matamoros, and it was not adequate. And so I
18 asked for another letter, and Mr. Matamoros or Mr. Calero —
19 I'v« forgotten which— asked me for some copy items which I'd
20 like to have included in it, and I provided them to them.
21 And the letter was reproduced and sent to me.
22 Q Do you recall what was inadequate in the first
23 draft that was produced by Mr. Matamoros?
24 A The first draft was a very short contract for
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that was inappropriate for Mr. Channell's understanding or my
understanding. And 1 think it even offered a percentage, if
I recall correctly. And it was clear from the content of the
letter that it had been misunderstood. So we asked for
something a little more direct and more consistent with what
Mr. Channell wanted to do.
Q Did Channell request you to seek this letter for
him?
A Yes.
Q Was it your understanding that Channell wanted a
letter like this to use in fundraising activities?
A Yes.
Q Was there any understanding, to your knowledge, as
to the fees or compensation that Mr. Channell would derive
from fundraising on behalf of the FDN?
A Yes. That's precisely the reason why the letter
was redone. He was not looking for any compensation from the
FDN for fundraising purposes. All he wanted was a letter
asking him to help. And that's basically what this is. It's
written a little more flowery than just please help. But
that's exactly what he wanted — an appeal letter from Mr.
Calero to him at his organization.
Q Was it your understanding at the time that Channell
didn't intend to make any money off of fundraising for the
contras?
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A That's correct.
Q What was understanding as to why Channel 1 wanted to
engage in fundraising for the contras?
A He was politically committed to supporting the
president. He was politically and personally conunitted to
seeking to help the democratic resistance in Nicaragua.
Q On what do you base that understanding? Or on what
did you base that understanding at the time?
A On my conversations and the direction his program
had taken.
Q Was it your understanding that Channell and his
organizations would deduct expenses incurred from monies that
were contributed for the contras?
A I can't tell you exactly when I became aware of
that. Initially no, other than normal operating overhead.
But some time in late '85 — maybe late summer, early fall of
1985 he told me that they would be deducting — I believe it
was 20 percent — from the donations for assistance.
Q Did you have a response to that?
A I think I informed Colonel North about it. And I
may have even taken it upon myself to say that's fine
initially. Because anything was greater than zero.
Q Did North approve of Channell taking this 20
percent, as you recall?
A I don't think I sought his approval. I just simply
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told him that Channell was retaining 20 percent within his
organization of the contributions.
Q Are you clear about the 20 percent figure?
A Yes.
Q At least that's the figure you recall Channell
having told you they were going to be taking from the
contributions.
A Correct.
Q When did that conversation take place, as best as
you can recall?
A The only mental trigger I have is a contribution by
Barbara Newington, which I think was in the amount of
$400,000. So whenever the first one of those was. I think
it was December. But the initial Ramsey contribution went
directly to the Nicaraguan Development Council. The second
Ramsey contribution went directly toj
Q What was the motivation, if you know, for beginning
to direct contributions into NEPL, as opposed to Channell
soliciting contributions from individuals and having them
directed directly to contra organizations?
A I have to answer it in different parts. From the
perspective of Colonel North and myself, the first and
foremost concern was an insulation between the donor and the
recipient.
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From Channell's perspective, the insulation was
important because he didn't want to receive a deluge of
unsolicited requests for funds. And also from Channell's
perspective, he did not want his donors in a position of
being in direct contact with the Nicaraguan resistance
because again they would be then deluged by a series of
requests. That seems standard operation in fundraising.
Q And he preferred that they be deluged with a series
of requests from him as opposed to some other organization?
A Well, without accepting the characterization, as I
understand it from my observations of Mr. Channel 1 and his
fundraising activities, people who give those sums of money
only like to do it for very specific programs or very
specific items. And if you ±)egin to go to them all the time
with little nickel-and-dime needs, they quickly turn to
someone else. They like direct, coherently presented
objectives which they can fund.
That's part of the reason for that insulation and I
suspect part of the reason for Mr. Channell's success.
Q Do you believe that between April or May of 1985
and the conversation you had with Channell in which he told
you he was going to begin to take 20 percent from donations
that Channel in fact was passing along all the money that he
was receiving as contributions for the cause of the contras?
A Either passing it along or using it for public
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education efforts, yes, since some of the people gave to both
things .
Q This is not intended to sound quite as facetious as
I think it's going to sound. Did you think that Channell and
Conrad were conducting all the activities which they were
conducting raising funds for the contras under the NEPL
umbrella out of the goodness of their heart for six or seven
months?
A I thought their first priority was assisting the
Nicaraguan resistance and that assistance took for them —
because we had conversations about it — it took for them two
forms. The first was direct assistance. And the second was
the programs maintained by their organization which was
designed to increase public support for the resistance and, in
the case of their political organizations, political support
for the resistance here on Capitol Hill.
So I felt always that their objectives were to help
the resistance. And I think — in full candor, I think they
spent their money that way.
Q But you don't have any basis for that.
A I have not seen anything to indicate otherwise.
Q To your knowledge, was one of the reasons for
inserting NEPL between the donor and the ultimate recipient
to provide the donor with a tax deduction for the contribu-
tion?
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A In terms of the public education effort, that was
quite certainly the reason for it. Can we go off the record
for one second?
MR. KAPLAN: Could the reporter please read the last
question?
MR. MILLER: I think you're recording over the top
of another answer, aren't you? No? I'm sorry.
So in terms of the political efforts and the public
education efforts, it was quite certainly one of the reasons
it was done .
In terms of resistance assistance, I'm not fully sure
what Mr. Channell's motivation was. But I did not consider
it at the time as one of the reasons for doing it.
BY MR. KAPLAN:
Q Is there a reason why NEPL was inserted between the
donors and the ultimate recipients in addition to IBC and IC,
Inc., to your knowledge?
A Well, as I previously stated, Mr. Channell wanted
that insulation for his donors . His donors wanted the
insulation, and he was the one doing the fundraising, so it
was appropriate to agree to that .
Q Did you ever discuss with Mr. Channell or--maybe
more appropriately — did Mr. Channell ever discuss with you
that one of the reasons why to insert NEPL into the network
was because it would be more enticing to potential con-
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tributors or prospective donors to be able to offer a tax
deduction to them?
A Actually, the opposite is true. Mr. Channell told
me one tiine--and it stuck in my memory quite explicitly--that
people who gave these very large sums of money were uninter-
ested in the tax ramifications of it, that they did it for
reasons of personal conviction. He used to call them
warriors, and they — his statement to me was that tax-
deductible status has nothing to do with the way these people
make their decisions. And I derived from that the notion
that it was unimportant to these people.
Q Did you believe him?
A Oh, I think it's borne itself out to be true. I
think all these people gave because of their personal,
convictions and patriotism and not because of tax-deductible
status .
Q Would you feel otherwise if you were told that most
all of these people who gave to NEPL during the relevant time
period indeed took tax deductions for their contributions?
A No, in that you're saying all the people who gave
to NEPL. And the point is I don't think anybody has ever
challenged the tax-deductible nature of the public education
effort. I don't think the Internal Revenue Service has
challenged it. So the public education effort, which was
actually larger than the assistance effort, was well within
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the confines of the regulations governing NEPL.
So when you say "all", no, I don't. I wouldn't be
taken aback by that at all.
Q What if you were told that several of the persons
who gave money for direct contra assistance, according to
your prior testimony and according to testimony of others
heard by the conunittees, took tax deductions for those
contributions ?
MR. DUDLEY: Is the question would that change his
view as to whether they really cared about tax deductions?
MR. KAPLAN: I don't see what that's got to do with
it.
MR. MILLER: Well, may I answer the question,
because you characterized it- incorrectly. He said "care".
What Channell said to me was their primary motivation was not
the tax deductibility. It was having a personal commitment
to a philosophical position or to something that they had a
personal — I've forgotten the word I used — but anyway, that's
different than whether they ultimately availed themselves of
the tax-deductible status.
I think if they thought they could, they'd be fools
not to. And they're all very wealthy people, and they didn't
get wealthy being foolish. So I think probably they probably
decided to take a tax deduction if they thought one was
warranted .
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MR. KAPLAN: I won't accept your characterization.
I know that there are some of mine that you probably won't
accept.
On May 6th of this year, did you plead guilty to an
information charging you with one count of defrauding the
United States under 18 United States Code Section 371?
MR. DUDLEY: As his lawyer, I will object to that
characterization. It was not a count of defrauding the
United States government. It was a count of conspiracy to
defraud.
MR. KAPLAN: That's correct. And that is what 18
United States Code Section 371 provides. And I apologize for
the mis-statement.
MR. MILLER: That's correct.
MR. KAPLAN: And was it your understanding in that
plea of guilty that the use of NEPL's tax exempt status was
wrong or was unlawful in connection with the direct contra
assistance effort?
MR. MILLER; As I understand it —
MR. DUDLEY: Let me finish the question, and then
let me talk before you start answering.
Have you finished the question?
MR. KAPLAN: Yes.
MR. DUDLEY: I object to the point of the question
on the grounds I think that you're asking him for some rather
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tricky legal conclusions here. And I have a problem with the
breadth of it, because it may well be that not all the
contributions for direct assistance would have been in any
way, shape, or form wrong. And I don't want him to answer a
question that's in a very sensitive area like that without
perhaps some minor distinctions being observed.
MR. KAPLAN: I accept that, and I withdraw the
question.
I'm not trying to lead you into a trouble area.
You just gave some testimony, some of which was maybe even a
bit non-responsive about the view of the use of NEPL's tax
exempt status with respect to the fundraising efforts for
direct contra assistance and certain direct contra assistance,
which we'll get into a little later today.
And my concern is that as I listened to that testimony,
it didn't strike me as being entirely consistent with the
plea of guilty to the information to which we've just
referred. And I wouldn't want to have the reflect an
inconsistency with what's a matter of public record, because
we are, after all, committees who are creating a record that
we want to have consistent with what's known to the public
and part of a judicial record filed in Federal District Court
in Washington, D.C.
If that inconsistency that I perceive can either be
cleared for our record, then I'd like that clarification.
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MR. MILLER: Well, I can't attempt to —
MR. DUDLEY: Let's go off the record a minute.
Q Is it your understanding, Mr. Miller, that NEPL's
tax exempt status was never misused in the solicitation of
contributions for direct contra assistance?
A No, that is not true. It is my understanding that
it was misused.
Q And briefly, could you explain in what respects you
believe that NEPL's tax exempt status was misused in that
connection?
MR. DUDLEY: I have a problem with this line of
inquiry, and I guess I may as well put the problem on the
record because I don't understand what relevance his under-
standing as a layman of the -legal issue with respect to the
misuse of NEPL's tax exempt status. I don't understand the
relevance of that to any line of inquiry that the Committee
has.
He can tell you about what in fact was done and
what he knew at the time it was done. It seems to me those
are perfectly relevant inquiries. His understanding of the
legal concepts as we sit here doesn't seem to me to be
relevant and quite frankly may entrench upon areas that I am
not sure he is competent to testify to.
MR. KAPLAN: I didn't intend to entrench on any
areas in which he was competent to testify, and I am certainly
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not asking Mr. Miller to draw any legal conclusions. I
simply was seeking a response to the question following on
the prior answer of Mr. Miller's as to in what respects he
believed the tax exempt status of NEPL was ever misused or
was misused in connection with direct contra assistance fund-
raising efforts.
That certainly is an area that is within the focus
of both the Committee's mandates. And to the extent that it
is going to impinge on any attorney/client communications, I
have no interest in the answer. I am asking for his under-
standing. It really is a follow-up to an answer that he gave
to a previous question.
Let's go off the record for a minute.
MR. LEON; Off the- record.
(Off the record.)
MR. KAPLAN t I am going to ask for an answer to my
pending question.
MR. DUDLEY: I am not quite sure what is on the
racord and what isn't, but I will want my objection noted
that it calls for legal conclusions that he is not competent
to make.
THE WITNESS: As I understand it, Mr. Channell
offered to contributors the capacity to deduct the contribu-
tion for assistance to the Nicaraguan resistance, which he
knew not to be deductible, and I was a participant in that
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conspiracy.
BY MR. KAPLAN:
Q And did you have contemporaneous knowledge at the
time that these deductions were offered that Mr. Channell was
offering deductions that were not appropriate at the time?
A Not that I can specifically point to.
[Witness and attorney consult.]
A If I can amend my previous answer —
Q Sure .
A — instead of the word "assistance", I think it
should be "for the purchase of arms".
Q And do you recall when you came to the understanding
that this use or misuse — this use of NEPL's tax exempt
status was indeed a misuse of that tax-exempt status?
A I can't. It was a growing understanding, culminat-
ing May 6, 1987.
Q Okay .
Did there come a time when NEPL began to give money
to IBC or to IC, Inc. that was intended to be provided for
assistance to the contras?
A Yes.
Q When did that occur?
A It began receiving contributions from Mr. Channell
in, I believe, July of 1985.
Q And did those contributions come from Mr. Channell
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as the result of the conversation that took place at a dinner
on July 9?
A I don't think that is the right date, but it was in
July that there was a dinner -- there was a meeting, not a
dinner, in the Hay Adams where Colonel North directed Mr.
Channel 1 to send the contributions to IBC.
Q You have testified previously as to the date of
that meeting, I believe. We can amend that testimony to
insert a different date, if that will be useful.
Do you recall a date other than July 9th?
A I don't recall July 9.
Q Okay .
A I don't recall another date specific.
Q Okay.
A The independent counsel is using, I believe, the
15th, is it?
MR. DUDLEY: I think July 9th.
THE WITNESS: Oh, July 9th; okay.
MR. DUDLEY: I think his problem wasn't so much
with the date as with the characterization of it as a dinner.
MR. KAPLAN: Okay.
BY MR. KAPLAN:
Q Well, at this meeting were Channell, Conrad, North
and yourself in attendance?
Yes.
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Q And at the meeting to which you testified on June
23rd here with us. Is that correct?
A Yes.
Q Do you recall with any better specificity the date
of the first payment from NEPL to IBC that was related to
direct contra assistance?
A I don't recall specifically what —
Some time in July of 19857
It seems to me that it was in July of 1985.
Do you recall the amount on that contribution?
As I sit here, no, but I am sure it is in my
Q
A
Q
A
records .
Q Okay .
Did you continue to receive payments for direct
contra assistance from NEPL through November of 1986?
A Yes.
Q Okay .
And when I say did you continue to receive, I am
referring to either IBC or IC, Inc.
A Yes.
MR. DUDLEY: What was the date and the question?
I'm sorry.
MR. KAPLAN: November 19th.
BY MR. KAPLAN: How did you segregate the payments
from NEPL that were intended for direct contra assistance
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from those payments from NEPL which you attributed to fees
owed for services performed by IBC?
A You have the cart before the horse.
Q Yes.
A Since our primary responsibilities were for
managing the public education and lobbying efforts, it was
easy therefore to take those things that were in addition to
those required charges, and they were easily identified. If
you look at them the way you have, then you would be confused.
But if we are in day-to-day operation and we are receiving
fees for television documentaries, for retainer fees and for
things of that nature, then when we get an additional amount,
it is either announced to us or is something which is in
great excess of anything we need, it is clear that it is
assistance money.
[Witness and attorney consult.]
BY MR. KAPLAN:
Q Based on your conference with counsel, do you wish
to add anything to your previous answer?
A No.
Q Okay.
Do you recall the approximate amount of NEPL
payments to IBC, that is total payments, from July 19 85 to
November 1986?
A It's in excess of $5 million.
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Q Okay.
And do you recall what the total amount was that
was designated for direct contra assistance?
A I have recently finished the computations on it,
and it is 53.44 million.
Q Okay.
And when you say you recently finished computations,
what records have you used in order to do your computations?
A The same ones you have, the invoices and receipts,
bank records .
Q Okay .
Who determined the timing and amount of payments
from NEPL to IBC for contra assistance?
A Mr. Channell.
Q Now the difference between the $5 million total
payments you received from NEPL between July 1985 and
November 1986 and the payments that your computations show
were used for direct contra assistance is about $1.56 million
or maybe a little more, I take it just from your testimony
this morning.
Was that remaining eimount considered to be payment
by NEPL to IBC for fees for services and any disbursements
expended in the performance of those services?
A Yes.
Q What services exactly gave rise to the, let's call
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it to round it out, $1.6 million of fees during that 15 or
16 -month period?
MR. DUDLEY: Fees and expenses.
BY MR. KAPLAN:
Q Fees and expenses.
A I mean, you have asked for an encyclopedia. In the
general category, media relations, lobbying activities,
legislative analysis, administration policy analysis, program
items such as writing of text, creation of documents, and
research into policy and implications of legislation on
policy.
We operated a speakers ' bureau . We produced
several films, television documentaries. We maintained film
crews in the border region
and in some cases they went into Nicaragua. We maintained
film crews in Nicaragua and Managua.
We produced text for ads. We produced news release
materials, statements. We produced graphics. We produced
slides. We produced brochures. We produced books. We
produced briefing books. We set up meetings between NEPL
people. Administration officials. Congressional officials,
media people, state and local officials, industry officials,
private citizens' groups.
We provided the Washington coordination for the UNO
leadership's Washington activities in 1986. We provided
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long-term strategic planning documents. We provided scenario
analyses of activities by the resistance forces. We provided
liaison with the resistance forces and NEPL officials. We
provided briefings for NEPL contributors. We provided -- I
don't know how long you want the list to get. That's as much
as I can remember right now.
We handled — in the area of Central America, we
handled the Central American Freedom Program and its original
-- its originator which had a working title of the Sacher
program and the Central American Diplomacy Program. We
handled the strategic defense initiative program for the
Endowment and for Sentinel. We handled constitutional
minutes program for the National Endowment. We handled a
South African Program for th.e Endowment. We handled a
terrorism program for the endowment.
We assisted in setting up one of the political
action committees, and other duties as a side.
Q Did you ever read Jerry Lucas' memory book?
A NO.
Q Very good recitation of the services that you
provided going back a couple of years ago.
MR. DUDLEY: Jerry Lucas, as I understand it, can
do the Cincinnati phone book.
BY MR. KAPLAN:
Q Were there invoices supporting the fees and
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expenses' portion of the NEPL payment?
A For many of the fees and services, yes, we did have
invoices .
Q Do you know approximately for how many of the fees
and services' portion was supported by invoices?
A I never totalled that up, so I couldn't answer.
Q Okay.
When did you start issuing invoices to NEPL for
your fees and services?
A I think we started in December of 1985. It was an
attempt to kind of get a handle on things because they had
been so frantic and so all-consuming in their activities that
we were — I was trying to get a handle on it, and so was Dan
Conrad .
Q How much of the $1.6 million —
(Brief discussion off the record.)
BY- MR. KAPLAN:
Q I think I had started into a question. How much of
the $1.6 million was attributable to fees, and how much was
attributable to expenses, to the best of your recollection?
A I really have not sat down and done a division on
it.
Q We discussed a little earlier the basis for your
fees, and I take it that with respect to this $1.6 million,
that basis that you described earlier this morning would
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apply. Is that correct?
A Yes.
Q So that a number of the projects for which you
performed services were charged to NEPL on the basis of your
estimation of what appropriate fees for the project should be.
A Correct.
Q Okay.
Do you have any breakdown as to what percentage of
your fees related to work performed for NEPL having to do
with the contras or with Nicaragua?
A No, I have never done it that way.
Q All right.
A I have attempted to quantify the total during the
period and have given Mr. Channell a report that had a total
figure for both, which was I think about $1.4 million. I
think that's right.
Q What would that $1.4 million be?
A They are really all fees to IBC and all expenditures
by IBC on MEPL's behalf for the programs.
Q For all programs?
A For all programs .
Q Okay.
And can you approximate for us approximately how
much of that $1.4 or $1.6 million, as we have been talking
this morning, related to NEPL projects in connection with
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Central America or Nicaragua?
A I have never done the math on it, so I really — I
mean, at this point I think it would be almost impossible for
me to do it. I would say it is at least half. That's about
as arbitrary as I can be. I would say it is at least half.
Q Okay .
A It was their largest program.
Q Okay .
During the period, how much of IBC's total income
was attributable to NEPL7 And I am still talking about the
period from July of 1985 through November of 1986.
A You want to know how much of IBC's income is
attributable to NEPL in the period between —
Q July 1985 and November 1986.
A I have never quantified it, but I would say it's at
least a third.
Q If I told you that on the basis of records we have
received from IBC and its financial institutions and from
NEPL and their financial institutions that IBC's total income
attributable to NEPL was 84 percent over that time period,
would that surprise you?
A You would have to be including the money that went
to the assistance.
Q That's right.
A Then that is an erroneous figure.
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MR. DUDLEY: That's got nothing to do with nothing.
THE WITNESS: But we can do the math right now, if
you want to. I am not being facetious. You take 84 percent
of $5 million and take away $3.44 million, and that is what
your percentage is. It would be considerably less than 80
percent.
BY MR. KAPLAN:
Q Okay. So basically, as I understand it, NEPL's
total income during that period was somewhere in the neighbor-
hood of about $6 million.
MR. DUDLEY: You mean IBC's.
BY MR. KAPLAN:
Q I'm sorry. I stand corrected. IBC's total income
during that relevant period was -- including the direct
contra assistance payments was somewhere very close to $6
million.
MR. DUDLEY: The problem I have with that is your
characterization of the direct contra assistance programs as
income to IBC, a position that we do not accept.
MR. KAPLAN: Okay.
BY MR. KAPLAN:
Q Then is it fair to say that under the way you
calculate income that IBC's total income during the relevant
time period was about $2.5 million, that is from July 1985
through November 19867
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A Where are you coming up with the $0.6 million, that
is my problem? I don't have my records in front of me, so I
can't tell you what our total 1985/1986 income was.
MR. OLIVER: He subtracted 3.44 from 5 million.
That's where it comes from.
THE WITNESS: Yes, but it's apples and oranges.
You take the $5 million and subtract 3.44. Then what came to
IBC from NEPL was 1.6.
BY MR. KAPLAN:
Q And I believe that the records that have been
submitted to the Committees by the various entities that I
described a moment ago showed that IBC during that time
period had additional income of approximately $1 million.
A Over and above the. NEPL income.
Q Right; that is right.
MR. DUDLEY: Now if that concords with your
recollection, tell him so. If you have no recollection —
THE WITNESS: I don't have a recollection of a
specific figure. I have never looked at it in those terms,
and I would want to before I accepted any characterization.
BY MR. KAPLAN:
Q Have your computations shown what IBC's total
income was for 1985 and 1986?
A I have never done a total IBC income computation
for 1985/1986.
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Q Okay.
The computations that you have done recently, were
they done at someone's request?
A The Internal Revenue Service.
MR. KAPLAN: Okay. Can we go off the record for a
minute?
MR. LEON: Off the record.
[Brief discussion off the record.]
BY MR. KAPLAN:
Q How were the direct contra systems payments from
NEPL to IBC treated by IBC?
A As client reimbursable expenses.
Q What were they considered to be reimbursements for?
A You can't use that as an English language transla-
tion. It's an accounting term that has to do with the fact
that you were not taking possession of the money. You were
simply passing it on at the behest of the client.
Q Okay. I appreciate that.
Is the treatment of these monies as client reimbur-
sable expenses a treatment that was arrived at from consulta-
tion with counsel?
A Consultation with our accountants.
MR. KAPLAN: Let's go off the record.
(Discussion off the record, and consultation
between witness and attornev
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THE WITNESS: In answer to your question, the
accounting treatment of the NEPL assistance money is something
that's under consideration at the moment between counsel and
myself. And I don't have a specific answer for you at this
time.
BY MR. KAPLAN:
Q At the time that the payments were made by NEPL to
IBC for contra assistance, how did you treat them? That is,
how did IBC treat those payments for tax purposes and/or for
internal accounting purposes?
A Again I think I have to give you the same answer,
from an accounting and a tax standpoint.
Q So they were treated as client reimbursable
expenses?
MR. DUDLEY: Off the record.
(Discussion off the record.)
MR. KAPLAN: Back on the record.
MR. DUDLEY: The issue of the tax and accounting
treatment of payments received by IBC for assistance — from
NEPL for assistance to the Nicaraguan resistance. It is a
matter that is in a state of flux. The payments were
initially characterized in 1985 on the books of the corpora-
tion as client reimbursable expenses.
It is not clear how they will be characterized
either for tax purposes or actually in the final books of the
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corporation for 1986. The tax returns for 1986 have not yet
been filed. The company is under extension, and the issues
are the subject of intense current discussion between Mr.
Miller and his counsel.
MR. KAPLAN: I appreciate that statement.
One more question on the subject before we get off
it entirely.
BY MR. KAPLAN:
Q Did Mr. Channell or Mr. Conrad ever tell you how
these payments should be treated on IBC's books?
A No.
Q I lied. One more question.
Did Colonel North ever advise you as to how these
payments should be treated on IBC's books?
A No.
Q What did IBC do with the contra assistance payments
that were received from NEPL?
A We put them in the general IBC account, and we
disbursed them as directed by Colonel North.
Q How did you know what payments were to be attributed
for contra assistance?
A Normally Mr. Channell announced them upon their
arrival. In other words, he would bring a check and say this
is assistance money.
In the cases when we had to pick it up or it was
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sent over, again he would do the same thing.
Q Who determined the timing and amount of those
payments?
A Mr. Channell.
Q Channell did. All right.
Did North ever have any input to your knowledge as
to the timing and amount of the contra assistance payments?
A No.
Q That is your knowledge?
A The answer is still no.
Q Is it possible that North spoke with Channell or
Conrad as to the timing and amount of those payments without
you knowing?
A It's hypothetical.- I guess it's possible, but I
have no way of knowing whether that ever took place.
Q Okay.
A There was one instance in which Colonel North asked
for a specific amount of money prior to Mr. Channell raising
money through NEPL.
Q Would you describe that instance?
A It happened in 1985 in I believe June. And Colonel
North called me and said we need $30,000 desperately to the
people involved in the southern front. And could I find
somebody to give $30,000?
He didn't designate anybody for me to talk to. I
ISAIAI aAAir-8r-»%
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called Mr. Channell Immediately and asked him If he could
make a contribution or would one of his people make a
contribution? And he put me almost immediately in touch by
telephone with John Ramsey. And I explained the situation to
John Ramsey, and John Ramsey wired a contribution]
And subsequently I spoke to Mr. Channell. He
suggested a thank you letter to Mr. Ramsey. I contacted
Colonel North, and he said why don't you send a telegram my
name, and I did that.
Q This is the same solicitation that you testified
about back on June 23rd7
A Yes . So that would have been the only time where
he determined the amount for us to raise.
That's the only Instance that's responsive to your
question.
MR. KAPLAN: While we're on it, I an going to ask
the reporter to mark as Memo 12, Exhibit 12, a copy of a
document which was provided to us by your counsel, and ask
you whether you can identify that document?
[Exhibit No. 12 was marked for
identification. ]
THE WITNESS: Yes. It's a handwritten note of mine
in a spiral notebook I kept.
BY MR. KAPLAN: ..»-,»k| iftf^in^H
«i OHt
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Q Is No. 2, which states "okay on telegram," and then
has Mr. Ramsey's name and address beneath that, along with
Mr. Channell's name and address beneath that, are they notes
of a conversation, the conversations with North that you just
referred to about sending telegrams to those people?
A This is a list of items which I needed to ac-
complish, and the double-check means that I accomplished
them. So that would indicate that North okayed a telegram to
Reunsey and to Carl Russell Channell.
Q The telegram to Ramsey has been marked as a
previous exhibit during one of the previous sessions of your
deposition.
MR. KAPLAN: I'm going to ask the reporter as
Exhibit 13 a copy of the mailgram which purports to be a
mailgram from Colonel North to Mr. Channell, the text of
which reads, "Thank you for the help on such short notice.
We all appreciate your heroic efforts," over Colonel" North's
name.
(Exhibit No. 13 was marked for
identification. )
BY MR. KAPLAN:
Q Is that the mailgram that resulted pursuant to this
handwritten note and your conversation with Colonel North?
A Yes.
Q While we're on that handwritten note, and that is
mini Aonsrirf^
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Exhibit 12, can you tell me, Mr. Miller what the first note
on the page refers to which reads, "I believe North consider
it done on RR to Spitz's letter"?
A Spitz wanted a letter of appreciation from Ronald
Reagan for his ad campaign.
Q And was that letter issued to Mr. Channell to your
knowledge?
A I believe so.
Q Okay. Down on No. 3, where it says "can see slide
show, " do you recall what that note refers to?
A I'm sure it's Colonel North's slide show, but it
doesn't have anybody else's reference to it, so I'm not sure
what the meaning of it is.
Q Would this have been a slide show on Nicaragua?
A That's Colonel North's slide show.
Q Was it the same slide presentation that he made at
the June 27 briefing?
A 7es.
Q And that he made on several other occasions?
A Yes .
Q Was that slide show largely comprised of slides
that had been provided to Colonel North by you or other
associates at IBC, or Mr. Channell or other associates at
NEPL?
A No. There were some pictures in it that were taken
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by Frank Gomez ^^^^^^^^p^ which Colonel North had integrated
into a slide show. But all the rest were official declas-
sified photographs.
Q Going back to where we were before we got side-
tracked on that Ramsey solicitation, what did IBC eventually
do with the direct contra assistance payments after segregat-
ing them for contra assistance?
A We spent them according to Colonel North's direc-
tion.
Q Did IBC, prior to spending them for the most part,
send them along to IC, Inc.?
A Well, actually, I think the initial transfers went
to Lake Resources. There were transfers to
There was the money spent on the al-Masoudi misadventure.
And ultimately the objective was to move all the transactions
into a situation where it was money to IBC which was passed
immediately to IC, Inc.
And the final objective was to have money passed
directly from those who wanted to make contributions to IC,
Inc. And we did accomplish that in '86.
Q In '86. Do you recall when in '86 you instructed
NEPL to begin sending payments directly to IC, Inc.?
A I'm not sure of the specific date, but I think it
started somewhere around September.
Q Could it have been August of 1986?
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A Could have been the end of August.
Q At whose direction were these payments first passed
to IC, Inc., were then sent directly to IC, Inc.?
Did you tell Channell in August or September of '86
to send the contra assistance payments directly to IC, Inc.?
A Yes.
Q And did you make the determination that the prior
contra assistance payments to IBC would be passed to IC,
Inc., or was that a determination made by someone else?
A Well, Colonel North directed that they be sent to
IC, Inc. The original transactions which were disbursed
directly out of IBC were done so for expediency, not for dual
purposes, but simply because there wasn't time to get it to
IC, Inc., and then transfer -it from IC, Inc.
Q Did North ever give you a reason why he wanted the
monies transferred from IBC to IC, Inc. before ultimate
distribution?
A Well, we had several discussions about it, and some
which I discussed earlier with you.
The need for some insulation, and ultimately to
provide some secrecy to the transactions.
Q That was something that Colonel North expressed to
you?
A Sure. We were both very conscious of it.
Q Then who made the — opened that determination to
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instruct NEPL to begin sending payment directly to IC, Inc.
in August or September of 19867
A I did.
Q You did, all right.
Did you discuss that decision with Colonel North?
A I don't recall whether I specifically discussed it
with him
Q
A
What prompted that decision?
we were no longer involved in Mr. Channell's
general programs . And the organization that we had then
finished the charter change on in the Grand Caymans was
sufficient to handle the transactions without them having to
go through IBC. There was no reason any more for them to go
through IBC.
Q Did you ever tell Channell that IC, Inc. was an
offshore company?
A I'm sure I did.
Q Actually in August or September of 1986, the
company would have been called Intel Cooperation, Inc. by
that time?
A The first checks may have actually been to IC, Inc.
But eventually they actually made their NEPL checks out to
Intel Cooperation.
Q All right. Do you recall when you might have told
Channel that IC, Inc., or Intel Cooperation was an offshore
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company?
A I'm sure the seune time I told him to make the
checks out to that entity.
Q So that would have been sometime in the late summer
or early fall of 1986?
A Yes.
Q Do you recall, Mr. Miller, whether, before that
time, you ever told Channell that there was another step
beyond IBC in the direct contra assistance funding network
that NEPL and IBC were engaged in?
A I don't remember specifically telling him, but I
may have .
Q So your best recollection is that it wasn't until
August or September of 1986 -that Mr. Channell had an under-
standing that you and Mr. Gomez maintained the offshore
company were direct contra assistance payments, eventually
ended up before ultimate distribution?
A Well, I can't agree with your question because
you've assumed that he knew it was Mr. Gomez and myself. I'm
not sure he did know that .
Q What's your understanding of what he knew?
A He knew that there was an offshore organization
that was responsible for distributing these contributions.
Q To your recollection, the first time that he became
aware of that offshore company was in August or September of
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1986?
A Yes.
Q When, to your knowledge, did Mr. Channell first
become aware that you or Mr. Gomez were associated with that
offshore company?
A Probably not until this February, when I issued a
report to him.
Q When, to your knowledge, did Mr. Channel! or any of
his associates first became aware that Colonel North had some
informal association with this offshore company?
A I don't know what you mean by informal association
with the offshore company? I'm not sure he had one.
Q Let me rephrase the question.
When, to your knoviledge, did Mr. Channell or Mr.
Conrad first become aware that Colonel North was directing
the disbursements from IC, Inc. or Intel Cooperation?
A Not until February of 1987. That's totally right.
MR. DUDLEY: I know, but I just want to point
something out.
The question and answer are I think potentially
misleading, because I think if you asked him when did they
become aware that Colonel North had a role in directing the
expenditure of the funds that they were contributing, the
answer would be different.
MR. KAPLAN: I will ask that question since I think
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that's a good one.
BY MR. KAPIAN:
Q When, to your knowledge, did Channell or Conrad
first become aware that North was directing the ultimate
distribution of contra assistance funds that were paid by
NEPL to IBC or to IC, Inc.?
A I can't give you a specific date, but I would say
that throughout the fall and into the winter of '85, '86,
they became increasingly aware of his role. And by spring of
1986 were, I think, aware that he was coordinating this
activity.
Q Did you ever tell him that he was coordinating this
activity?
A I don't think I ever specifically told him he was
coordinating.
Q When you all left the table back in July of '85
from the meeting in which North suggested to Channell that he
begin sending contra assistance payments to IBC, what is your
impression of what Channell 's and Conrad's understanding was
at that time?
A That they were seeking Colonel North's advice and
consent and direction as to who should receive the funds .
And they got it, they got it, and the answer was to IBC.
Q I take it you understood that when North directed
the funds to go back to IBC that North would be involved in
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coordinating the operation and directing the ultimate
distribution of the funds?
A Of course.
Q Did Mr. Gomez have that Scune understanding to your
knowledge?
A No. He wasn't at the meeting.
Q But did Mr. Gomez come to that understanding at
some later point in time?
A Yes.
Q When did Gomez come to that understanding?
A Actually we had that understanding prior to that
meeting because that was the import of the al-Masoudi
business in April.
Q We're going to get to the al-Masoudi business but
probably not till tomorrow.
MR. KAPLAN: I think this is a good time for a
break for me.
[Whereupon, at 12:45 p.m., the taking of the
deposition recessed, to reconvene at 1:45 p.m., the same day.
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BY MR. KAPLAN:
Q Now, Mr. Miller, you testified this morning that
approximately $3.44 million of money was given to IBC or to
IC, Inc. by NEPL for the purposes of direct contra assistance.
Who directed the distribution of those funds beyond IBC and
IC, Inc.?
MR. DUDLEY: I don't want to quibble with you. I
don't think he testified to that. I think those numbers were
yours, and he said he didn't have his data in front of him
and didn't dispute the numbers.
THE WITNESS: 3.44 is my number.
MR. DUDLEY: Okay. Then I am wrong.
THE WITNESS: 3.44- was distributed — was given by
NEPL by IBC to be given to the resistance.
BY MR. KAPLAN:
Q Okay.
And I take it some of that was also given to IC,
Inc. as well?
A Yes.
Q Who directed the disbursement of that money beyond
IBC or IC, Inc, as the case may be?
A Colonel North.
Q And who determined the timing and amount of those
disbursements?
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_ 1 A Colonel North.
2 Q Okay.
3 And how were those disbursements accomplished?
4 A Normally by wire transfer. And I sent instructions
5 to either my bank here or the bank in the Cayman Islands, or
6 rather I sent instructions to the managing directors who then
7 sent instructions to the bank.
8 Q How did Colonel North know that IBC or IC, Inc. had
9 some contra assistance money on hand to be disbursed?
10 A I would have informed him when we received it, and
11 we had for 1985 a running balance sheet, and in 1986 we also
12 had a running balance sheet.
13 MR. KAPLAN: I will ask the reporter to mark as
14 Deposition Exhibit Number 14. a copy, a composite exhibit,
15 which consists of what purports to be — the specifics are
16 not important for purposes of my questioning — what purports
17 to be a telex, I believe, from IC, Inc. to Mr. David Piesing,
18 and that telex is dated June 13, 1986, and then attached to
19 it for purposes of Exhibit 14 is what purports to be a letter
20 identical to the telex, both signed by you and Mr. Gomez.
21 (Whereupon, Deposition Exhibit
22 Number 14 was marked for
23 identification.)
24 BY MR. KAPLAN:
mUMD HMOWIWU CO., MC
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A Yes.
Q All I wanted to ask about these, is this letter and
telex representative of the telexes and letters that you
would send to the Cayman Islands pursuant to Colonel North's
instructions for distribution of money from the IC, Inc.
accounts?
A Yes.
Q would Colonel North typically give you the name of
the recipient of the funds?
A On some occasions he gave me the name. At this
point, I know pretty much all of them, but at the time he
gave me the actual account and the information associated
with it that was necessary for me to make the transfer.
Q Okay.
Was that true in all instances that he would give
you either the name of the recipient or both the name of the
recipient and the account number?
A Yes.
Q I am going to run through a list of recipients that
you compiled on the basis of information provided by a
variety of entities, including IBC, and ask you to just tell
me what you know about the nature of the organization and how
much money they received through the NEPL, IBC and IC, Inc.
channelling of funds.
A I am not always going to be able to recall the
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exact figure though.
Q Okay. In any event, I can give you figures, and
you tell me whether that seems right.
Was there a Carlos Ulvert?
A Yes.
Q And was that a recipient to whom money was directed
by Colonel North?
A Yes. That transfer that you are describing is part
of the $100,000 budget for the establishment of the Washington
Office of the Unified Nicaraguan Opposition, and Mr. Ulvert
was Executive Director.
Q And did Colonel North give you the account informa-
tion for the transfer of funds?
A No . He told me to. work that out with Robert Kegan
at the State Department, and Mr. Kegan put me in touch with
Mr. Ulvert and at subsequent meetings Mr. Ulvert gave me the
account information.
Q Okay. Was Mr. Kegan involved in any other transfers
of funds from the NEPL, IBC, IC, Inc. network?
A Not that I am aware of.
Q Had you known Mr. Kegan before Colonel North
referred you to him?
A Yes.
Q Did you know him from the time that you had spent
at the State Department?
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UNCLASSIFIED
_ 1 A Yes.
2 Q We have got on our records a $10,000 payment to Mr.
3 ulvert directly. You mentioned that that was part of a
4 larger $100,000 payment. Where did the other $90,000 come
5 from or to whom was it paid?
6 MR. DUDLEY: The $100,000 budget is what he said.
7 THE WITNESS: The actual dollar amount paid was
8 $100,244.10. I think that is correct. There was $10,000 to
9 the account of Mr. Ulvert. There was $11,000 to an account
10 in Miami. There was —
11 BY MR. KAPLAN:
12 Q Wasn't that account in the name of Denise Ponce?
13 A There is more than one account in Miami, but off
14 the top of my head I think that is the one.
15 Q Okay.
16 A There was $15,000 to a gentlemen by the name of
17 Katyal who was the landlord and the owner of the building.
18 Q Here in Washington?
19 A Here in Washington.
20 There was $55,750 paid to a bank here in Washington,
21 which represented the balance at the time. In addition, we
22 paid out of IBC accounts $1,500 to Wynmark Corporation, who
23 were the real estate agents who secured the property for us,
24 and the balance of the rent of $4,500 was paid to Katyal. In
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think that is where that comes from. And we secured the
telephones deposit, which we got backs. --.. _
I don't think I left anything out. I think that
basically is aboutjL $100,000 .
Q The $55,700 payment-, was that made to a bank on
behalf of an entity or an organization called Latin American
Finance?
A I'm not sure that is the name of the entity. I
think that is the bank's designation for its Latin American
section.
Q I see.
A So whatever the bank was — it seems to me it was
First American Bank or something.
Q But the payment itself would have gone to something
called Latin American Finance?
A Correct.
Q And were all those payments directed by Colonel
North?
A The $100,000 was directed by Colonel North and he
instructed me to undertake the activity, and I kept him
informed of the expenditures .
Q Okay.
A And I got the final approval for the final expendi-
ture of $55,700; I got his approval because that would have
wiped out the account
UNCUSSIFIED
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Q Our recorda show that Mr. Calero and accounts
controlled by him were Alpha Services, Inc. — received
approximately $1,030,000 from the IC, Inc. account.
A That's correct.
Q Is that in Keeping with your records or close to it?
A Yes.
I think his total figure is 51,230,000.
Q Were those disbursements also directed by Colonel
North?
A Yes.
Q Were they directed to accounts identified to you by
number by Colonel North?
A Yes .
Q The computation w» have done shows approximately
$31,000 were distributed to^^^^^^H Is that reasonably
consistent with your recollection?
A NO, actually it is $41,000. There was a $10,000
wire transfer from the National Bank of Washington communica-
tions account for a total of, I believe, $41,000.
Q
A
Q
North?
A
Q
Right. And 31 would have come from IC, Inc.?
Correct.
were both of those transfers directed by Colonel
Yes.
And were tli^y'directed'tjorjaccounts by number by
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Colonel North?
A Yes.
Q
$125,000
A
Q
A
Friends of America we show received approximately
That's correct.
What can you tell us about Friends of America?
Friends of the Americas is a humanitarian organiza-
tion operated by Woody and Diane Jenkins from Louisiana. It
provides medical care and feeding facilities for Meskito
Indians and Nicaraguan refugees
Q How did you arrive at that understanding as to what
Friends of the Americas was?
A I have known about- Friends for four years .
Q Did Colonel North direct the funds from IC, Inc. to
Friends of America?
A ^ Yes .
Q And did he provide you with bank account information
allowing you to direct those funds?
A Yes.
Q Okay .
Gulf? and Caribbean Foundation received from IC,
Inc. $21,182.
A Correct .
Q And th^ is former Congressman Kuykendall's
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organization.
A That ' s correct .
Q And did Colonel North direct the funds to be sent
to Gulf and Caribbean Foundation?
A Well, in an indirect way.
Q All right. Can you tell us what you mean by that?
A I was contacted by Colonel North and asked to find
an organization who would be willing to serve as the guarantor
of surgical procedures. In fact, I think he characterized it
as reconstructive surgery. And I agreed to do so. I called
Dan Kuykendall and asked him if the Gulf and Caribbean
Foundation would be willing to be the guarantor for the
surgery through a group of Miami doctors. He checked with
his Board and came back and .said that they would be willing
to do that . And we agreed that he would give me the name and
address. I gave the name and address to Fawn Hall, and the
hospital or doctors' organization sent the bills to Gulf and
Caribbean when they arrived. And they arrived on two
different occasions.
We sent checks from IC, Inc. to the Gulf and
Caribbean Foundation so that they could pay the bills. And I
believe that they charged a 1 or 2 percent overhead to take
care of the accounting and the check writing.
Q Our compilation shows that the Institute for
Terrorism and Sub-National Conflict received $75,000 from IC,
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Inc.
A That's correct.
Q Did Colonel North direct that disbursement as well?
A Yes.
Q And was the disbursement made to an account
identified by number by Colonel North?
A Yes.
Q Can you tell us what you know, if anything, about
the Institute for Terrorism and Sub-National Conflict?
A It's a foundation in Washington run by Neal
Livingston, and at the time of the transfer Rob Owen was
employed by them. And their principal focus is on sub-
terrorism and sub-national conflicts, and Nicaragua is a sub-
national conflict.
Q Did you come to any understanding as to how those
funds were used?
A The only understanding that I have is that in some
way it related to Rob Owen's being there. What the specifics
were I wasn't told.
Q Okay .
Our records show that approximately $1.3 million
was sent to Lake Resources from the IC, Inc. account and
apparently $4 30,000 was sent to Lake Resources from IBC
directly.
A That's correct.
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Q Were those disbursements, because there were
several, directed by Colonel North?
A Yes.
Q And were they, directed to accounts that were
identified to you by number by Colonel North?
A Yes.
Q Did you contemporaneously with those disbursements
have any understanding as to what the purpose, what the
function of Lake Resources was?
A Well, my original understanding was that it was an
organization for the benefit of the Nicaraguan resistance. I
never heard of Mr. Hakim until his name surfaced in regards
to this inquiry, and the only thing I had seen about General
Secord was the news report £ibout him buying an airplane
somewhere down south, in the southern part of the United
States .
And in regards to what we were raising money for,
we had some idea each time we spoke to contributors about the
specific items that we were raising money for. So we had
some understanding that the money transferred there was to
pay for those specific items.
Q And you are talking about specific lethal items.
A Both lethal and non-lethal.
Q Okay.
But I take it that you came to an understanding
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that when there were solicitations intended for the purchase
of lethal supplies that took place, that the money that was
contributed in response to those solicitations usually ended
up in Lake Resources ultimately.
A I don't think I ever made the connection between
those two things .
Q Okay.
Latin American Strategic Studies Institute received
some $50,000. Is that correct?
A It sounds right.
Q And did it also receive. $25, 000 directly from IBC?
A It did. That was part of the Central American
Freedom Program.
Q So a total of $75,-000 and all went to Latin
American Strategic Studies Institute?
A Correct.
Q Were those disbursements directed by Colonel North
as well?
A Yes.
Q All $75,000 worth?
A Yes.
The $25,000 was for a briefing book on Nicaragua,
and Colonel North asked that it be funded and Adolfo Calero
asked that it be funded. And we funded it out of the
resistance money.
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Q And I take it that the transfer was made to an
account identified by number by Colonel North?
A Correct.
Q What's your understanding as to the nature of the
activities conducted by the Latin American Strategic Studies
Institute with those funds?
A My understanding is that it was used for public
education and I have a letter from them, but I can't recall
what the specifics of it are, but public education.
Q How did you reach that understanding?
A I asked for a letter in response to a need to know
what they spent the money on.
Q Was Father Dowling an acquaintance of yours?
A Yes. I knew Father Dowling for about the same
period of time that I knew Spitz Channell. ,
Q Did you know that Father Dowling was one of the
principals in the Latin American Strategic Studies Institute?
A I did.
MR. LEON: You did or did not?
THE WITNESS: I did.
BY MR. KAPLAN:
Q A couple more questions about the $55,700 that went
to this Latin American Finance. Were you told what the use
of those funds would be at the time that the disbursement was
directed by Colonel North?
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A Yes. They were for the administration of the UNO
office in Washington salaries.
MR. LEON: Would you say that name again?
THE WITNESS: UNO Office in. Washington.
They were for the administration expenses and
salaries associated with the UNO Office in Washington.
BY MR. KAPLAN:
Q Just to clarify the record, my understanding of
your testimony is that Latin American Finance was a section
of the bank to which the payment was made for this purpose so
that the disbursement would read as a disbursement to
something called Latin American Finance. Is that correct?
A I don't know. My recollection is= that Latin
American Finance has more to do with the bank itself than it
does the recipient. The recipient was whatever the account
was for the resistance organizations.
Q Were you given an account number for that disburse-
ment as with the others?
A I was given an account for that disbursement by
Carlos Ulvert.
Q Okay.
What role did Mr. Kegan at the State Department
play in the coordination of the disbursement of this $100,000
plus a little to coordinate or pay expenses and salaries for
the local UNO office?
\m hmm
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_ 1 A Well, Colonel North called me on the telephone and
2 told me to get the Washington office operational and that my
3 contact in doing that would be Bob Kegan at the State
4 Department. And I called Bob Kegan and told him of the
5 conversation and suggested that I should meet with Carlos
6 Ulvert, the new Executive Director. Mr. Kegan arranged the
7 meeting. I asked Mr. Ulvert for a budget. He provided a
8 budget, and I went to Colonel North and discussed the total
9 figure with him, and subsequently got his approval to fund it.
10 Q Do you recall when these conversations took place?
11 A It seems to me it was about March. It's just about
12 the same time as the first transfer to Katyal.
13 Q I take it that would be reflected on the records
14 that you have provided us. -
15 A Yes, within 30 days of that period, 30 days prior
16 to that period.
17 Q So there wasn't a long lead time from the time of
18 those conversations to the actual payment, the coordination
19 of those payments?
20 A Ollie North had no long lead times. , It was done —
21 it was one of those things that was required to be done
22 immediately.
23 Q Could it have occurred some time within a month or
24 so of July 30, 1986?
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to be about a week or two prior to that.
Q Now the records we have show that there is really a
couple months' period between the Katyal payment and the
Latin American Finance payment.
A Oh, yes. Latin American Finance was the end of the
grant process.
Q I see.
A Basically, we were turning over to them the funds
to administer the office themselves.
Q So you had the conversations with Kegan and Kegan
referred you to Ulvert, and then you started making payments
to control the support purpose.
A Correct.
Q And one of the first payments was to Katyal, and
one of the last payments was to this Latin American Finance.
A Latin American Finance was the last payment.
Q Okay .
Do you recall a $10,000 disbursement from IC, Inc.
to the Nicaraguan Business Council?
A Yes.
Q Did Colonel North direct that payment?
A Colonel North approved that payment.
Q Okay. And when you say — I noticed that you
changed my wording to "approved" in this case. Can you
explain to me —
irity
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A Yes. Mr. Matamoros approached me and said that the
Nicaraguan resistance wanted to bring a group of Central
American Congressmen to the United States to be before
national media and to meet with officials in Washington, and
that it would cost $10,000. And he asked if I could give him
$10,000. I called Colonel North, asked his permission, and
he said yes, and I sent him $10,000.
Q I take it the Nicaraguan Business Council is
different from the Nicaraguan Development Council?
A That's correct.
Q The Nicaraguan Development Council received our
records show a $31,000 payment directly from IBC. Is that
correct?
A Actually, there were two payments, one of $6,000
and one of $25,000.
Q All right, combined.
Here those payments to the Nicaraguan Development
Council directed by Colonel North?
A Yes .
Q They were. Again, were they directed to accounts
identified by account number by Colonel North?
A In those two instances, each of them is slightly
different. The $6,000 was for travel expenses associated
with several of the UNO leaders coming to Washington,
expenses that the NBC had absorbed, and I was approached by
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Mr. Metamoros to pay those expenses, and I got Colonel
North's permission to do so.
In the case of the $25,000, that was $25,000 urgently
needed, again, by Mr. Metamoros for payroll taxes, and
attorney's fees, and general operating expenses for the NDC
office. And he approached me on it, and I contacted Colonel
North, and Colonel North approved the expenditure.
Q What can you tell us about the Nicaraguan Develop-
ment Council?
A The Nicaraguan Development Council is an organiza
tion in Washington, tax-exempt but I don't think tax-deduc-
tible. It is a organization that basically serves as the
domestic arm of the Nicaraguan resistance. One of the
domestic arms of the Nicaraguan resistance.
Q Similarly, what can you tell us about the Nicaraguan
Business Council?
A I really know nothing about the Nicaraguan Business
Council. Just that they were the sponsors of this group of
Congressmen.
Q All right. Do you recall a $60,000 disbursement
from IC, Inc. to an entity called Pigfield Enterprises?
A Pigfield Enterprises?
Q Right.
A No. Would there be another name associated with it?
MR. DUDLEY: Parkfield Enterprises?
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THE WITNESS: Where? What country was it disbursed
to?
MR. KAPLAN: I believe it was disbursed — can we go
off the record for a second.
[Brief discussion off the record.]
MR. KAPLAN: Back on the record.
THE WITNESS: Are you talking about a $40,000 and a
$20,000 transfer?
MR. KAPLAN: I believe that's correct.
THE WITNESS: One right after the other?
MR. KAPLAN: And it's to a financial institution in
Florida.
THE WITNESS: Yes. I recall that.
BY MR. KAPLAN:
Q Were those disbursements directed by Colonel North?
A Yes .
Q Were they to account numbers provided to you by
Colonel North?
A Yes.
Q And what can you tell us about those disbursements,
if not about Pigfield, or Parkfield Enterprises itself?
A At the time that those transfers were accomplished.
Colonel North told me that they were to assist the church in
Nicaragua to recover from the harassment that they had
suffered at the hands of the Sandinista government, including
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the smashing of the presses and the confiscation of printing
materials. And also, operation of the church organization
which had been greatly curtailed. There have been subsequent
revelations that that account is associated with Cardinal
Obando y Bravo, but I have no way to independently verify
that.
Q What about Polca, S.A.? Do you recall a $25,000
distribution to a recipient named Polca, P-o-l-c-a-, S.A.?
A Yes.
Q Was that a disbursement that was directed by
Colonel North?
A Yes.
Q Was it to an account identified by number by
Colonel North?
Yes.
What can you tell us, if anything, eUDout Polca,
S.A. 7
.A I don't have any idea who it is.
Q Okay. Do you recall when that distribution was
made, offhand?
A Late in 1986.
Q Late 1986. Was it some time prior to Colonel
North's having left the NSC?
A It was given to me prior to Colonel North leaving
the NSC. I don't know whether I accomplished it prior to his
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Q Okay.
A Because there's a great lag time between the time
he would pass instructions and the time they would be
executed by the managing partners in the Caymans. It's part
of the problem of doing business —
Q I see. What kind of lag time would there be
between the time that Colonel North gave you instructions,
and the time that you sent a Telex, and letter, as marked as
an exhibit earlier today, to the Cayman Islands?
A It really varied. It depended on his expression of
urgency. In some cases, the transactions were continuing,
such as $5,000 a month, or $7,000 a month, or 10,000 once a
month for the next three months, or something to that effect.
Q But generally speaking, when Colonel North gave you
instructions, you implemented them fairly promptly?
A As quickly as I could, yes.
. Q Do you recall disbursements totalling $60,000 to a
group called Friends of Freedom, directly from IBC?
A Friends of Freedom?
Q Right.
A No.
Q What about the same amount then, $60,000, to
Alfonso Robelo?
A Yes.
UNCLASSIFIED
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Q And did Colonel North direct those disbursements?
A Yes.
Q Again, did he direct them to account numbers that
were identified by him?
A Yes.
Q What's your understanding as to the uce of that
$60,000?
A That money was to support Mr. Robelo's political
organization^^HUHHHj pay his employees' salaries, and
newsletter cost, and travel expenses, administrative overhead
Q Was the contribution that you described earlier,
pursuant to the solicitation requested by Colonel North to
^^ also intended for Robelo's behalf?
A Yes .
Q IBC also distributed a total of $100,000 to an
individual named Gary Bagdasarian. Is that correct?
A Yes .
Who is Gary Bagdasarian?
He's an attorney for Ibrahim al-Masoudi.
And where is he located?
California. Fresno.
In Fresno. Was that part of your undertaking with
al-Masoudi, that you would pay his attorney's fees?
A Well, it was one of the expenditures that we paid
on behalf of al-Masoudi.
-Q
A
Q
A
Q
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Q Did Mr. Bagdasarian represent al-Masoudi in
connection with the criminal charges that were eventually
filed against him?
A I don't believe so.
MR. DUDLEY: PD in Philadelphia.
MR. KAPIiAM: So the record's clear, PD is a Public
Defender.
[Brief recess. ]
MR. KAPLAN: Back on the record.
MR. DUDLEY: Before we b^n^, there is one thing
Mr. Miller wanted to clarify.
THE WITNESS: I think you left the impression that
the money for Bagdasarian was for fees for Bagdasarian. It
apparently was not. In fact- it was represented to us at the
time that that's what it was for. It was for something
entirely different.
BY MR. KAPLAN:
- Q Do, you know what it was used for?
A It was used for a forfeited performance bond that
al-Masoudi supposedly had to forfeit. It was 104,000, total.
MR. DUDLEY: And what it was actually used for--
MR. KAPLAN: Was Bagdasarian the guarantor on the
performance bond? Is that what your understanding was?
THE WITNESS: No, no. It was al-Masoudi 's perfor-
mance bond. Bagdasarian was simply serving, I think, as a
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BY MR. KAPLAN:
Q What was the performance for? Do you know?
A I don't.
Q What was the source of the $100,000 that was paid
to Mr. Bagdasarian?
A That was assistance money.
Q Did Colonel North direct that $100,000 disbursement?
A Yes. He approved that $100,000 disbursement.
Q He approved it. So that I take it, then, you were
asked to make good on a $100,000 performance bond that al-
Masoudi forfeited on, and you called Colonel North and you
told him that you were asked to make good on this, should you
pay it, and he told you to pay it?
A Yes .
Q And did he tell you from which funds to pay the
$100,000?
A Well, we were only dealing with one set of funds,
and that was the assistance money.
Q And it was the assistance money that had been
passed to you by NEPL?
A NEPL and, at that stage, maybe also the Heritage
Foundation, and — well, at least one other contributor.
Q who was that one other contributor?
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A His name was Barness, B-a-r-n-e-s-s, and it was a
single check for $5,000 which I sent to IC, Inc. But all the
al-Masoudi money was assistance money.
Q And when you say "assistance money" you're referring
to money coming either from NEPL, from Heritage Foundation,
contributions, or to this $5,000 from Mr. Barness?
A Correct.
Q Other than Mr. Regan's invo-lvement , which you
described a bit earlier, to your knowledge, was anyone else
at the NSC and the White House, or in any other department or
agency of the United States Government, involved with or
knowledgeable of the contra funding network that you and
NEPL, and Colonel North were engaged in?
A Fawn Hall. Robert- Earl. I'd say that's about it.
Q To your knowledge, how would you describe the
extent of Fawn Hall's knowledge?
A Intimate. ^
Q And how did you arrive at that understanding as to
the extent of her knowledge?
A Well, sometimes instructions to me, by North, would
be passed through her, or a message would be passed through
her, and I might pass a message back. He was often out of
the office, out of the countiry, and Fawn was a reliable
communications source.
Q Was it clear from your conversations with Fawn Hall
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that — well, that she knew about the "goings-on" of the
operation?
A I would say — I'm probably not qualified to charac-
terize what she knew.
MR. DUDLEY: I'm not sure what "goings-on" are.
THE WITNESS: I really don't know hew to charac-
terize her state of knowledge.
BY MR. KAPLAN:
Q Did it appear from your conversations with her,
that she was aware of the nature of the activities?
A The general nature, yeah.
Q What about Robert Earl?
A Well, given that instance which I recalled to you
earlier this morning about the chart, I get some sense that
maybe Earl was a little more conversant with details.
Q Did you ever have any conversations with Earl, with
North, or with anyone else, that led you to the conclusion
that you just expressed?
A About Earl?
Q Yes .
A Yeah, but I can't recall any of them, specifically.
Q Did Earl ever give you any instructions with
respect to disbursements of funds, or the like, in connection
with the contra- funding activities?
A I don't remember any, specifically.
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1 Q Was John Roberts, to your knowledge, aware of the
2 nature of your contra-funding activities?
3 A No.
4 Q Was Elliott Abrams, to your knowledge, aware of
5 those activities?
6 A No.
7 Q Who, at NEPL, was aware of these activities, other
8 than Mr. Channell and Mr. Conrad?
9 A When you say "these activities", you're talking
10 about the assistance?
11 Q That's right. If you'll allow me, I'll refer to
12 them by the shorthand of "the network", but what I'm referring
13 to is the NEPL, IBC, IC, Inc., and beyond, funnelling
14 relationship.
15 A Well, at IBC there was only Frank Gomez and myself.
16 MR. DUDLEY: Who at NEPL?
17 THE WITNESS: At NEPL, I would say Spitz Channell
18 and J)an Conrad, Cliff Smith, and of course Littledale.
19 BY MR. KAPLAN:
20 Q And how would you describe--if you can — Cliff
21 Smith's knowledge?
22 A General. But I always got the feeling that the
23 solicitations for assistance money were done primarily by
24 Spitz.
mjjn Kpowrwo co.. inc , , i ^
ytTCSu^.Ni 25 Q And what about Littledale 's knowledge? How would
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you characterize that?
A Again, general.
Q How would you characterize Frank Gomez's knowledge
of the contra-assistance activities?
A Peripheral.
Peripheral . So —
Well, I don't know if that's the right word.
Feel free to give me more than a one-word answer.
Frank was knowledgeable about the transactions, and
was knowledgeable about the structure. The day-to-day
details were something that I attended to, not Frank.
Q And when you say "knowledgeable of the transac-
tions", what exactly do you mean by that?
A Well, his name had to go on the transactions just
as mine did, so he would have been knowledgeable about the
transactions.
Q Did he just come in and sign letters, or did
someone explain to him what was going on here?
A Both he signed letters and I received verbal
agreement from him when we transmitted Telexes .
Q And did he understand what the substance of the
letters he was signing were?
A Yes.
Q He did. And did he understand that he was a
necessary "spoke in the wheel"', so to speak?
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A Yes.
Q How would you characterize Jonathan Miller's
knowledge, if any, of the network?
A I don't think he had any knowledge of it; not from
me, anyway.
Q Are you aware of whether he had any knowledge of
the operation of the network from anyone else?
A Well, he was working for a while fairly closely
with Colonel North, and in fact was working out of his
office, Colonel North's office, for a while.
Q Was he engaged in the contra funding and fundraising
activities?
A I don't know that he was involved in fundraising,
but I know Frank has reported to me one instance when
Jonathan offered traveler's checks to one of the Meskito
leaders, and I think it was Diego Wycliff, but I'm not sure
which of the Meskito leaders it was.
Q When you referred to "Frank" a moment ago, you were
referring to Frank Gomez?
A Yeah. Frank told me about an instance in which he
was at the National Security Council offices, and in effect
he was doing the translation for Jonathan, and serving as
kind of an escort for this Indian leader, and Jonathan was
trying to convince him to become part of the resistance
movement. And as a show of his good faith, he held up
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several thousand dollars in traveler's checks and basically
offered financial support necessary for the guy to run his
organization as part of UNO.
Q I take it you're no relation to Jonathan Miller?
A No.
Q When was the World Affairs Counsellors, Inc.
established?
A April 1986. I believe the 25th.
Q Why was World Affairs Counsellors formed?
A The first, primary reason was to accept the 10
percent overhead charge which we began charging Colonel North
in the IC, Inc. and assistance transfers. And secondarily, we
wanted to do more of this type of business for resistance
movements or political entities — or, excuse me — international
foundations. And as a result, we also built into the charter
of that organization political, media relations, strategic
planning. That type of thing.
Q In your prior testimony, I believe that you
testified that it was some time in late 1985, that you
discussed with Colonel North your interest in charging 10
percent of the assistance funds that were passed to IBC, and
through IBC, is that correct?
A Right.
Q I take it that you specifically recall mentioning a
figure of 10 percent to Colonel North?
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A Yes. I do.
Q And you also testified, back in June, that Colonel
North commented to you something like, 10 percent would be
fine because most of the people in the contra-assiatance
business are taking 20 to 30 percent. Is that correct?
A Yeah. I think it was almost exactly his words that
he said, 10 percent is fine, most of the people involved in
this are taking anywhere from 10--or anywhere from 20 to 30
percent.
Q Do you recall the specific conversation in which
you first raised with Colonel North this interest of you and
Kr. Gomez wanting to dedsct 10 percent from the asisistance
payments?
A I don't remember the specific conversation. I
remember the basic elements of it.
Q would it have been in the context of coniversations
about other disbursements being made of assistance- funds?
A Well, one of the first and foremost reasons was
after the al-Hasoudi business, and working with the resistance
leaders, it became clear that this was costing us money.
I mean, we were using fees associated wiith other
activities to pay for our time associated with this, and al-
Masoudi had actually been money out of our pocket, and as a
consequence we thought we'd better start charging an overhead
fee or we were going to continue to lose money, and we
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weren't that profitable, that we could afford to do it.
Q I'm not going to mark as an exhibit, but I'm going
to show you a notation which I'll represent to you is from
Colonel North's notebook, dated November 19, 1985.
MR. DUDLEY: Off the record.
MR. KAPLAN: Yes.
[Brief discussion off the record.]
MR. KAPLAN: Back on the record.
I'd like the reporter to mark as an exhibit a page
of notations which our date stamp show were taken from
Colonel North's notebooks provided to the Committees.
I'd like to state, for the record, that this
Exhibit 15 has been reviewed internally, and determined that
there is no classified information that hasn't already been
testified to by Mr. Miller, or other parties, in connection
with these investigations.
The insertion of this page of Colonel North's
notebooks into the record in no way is intended as a waiver of
any classification and declassification procedure that
appropriately would apply to any other notes in the notebooks
produced to the Committees by Colonel North in connection
with his testimony.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 15.]
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BY MR. KAPLAN:
Q Mr. Miller, do you recognize the handwriting on
Deposition Exhibit 15?
A Well, I think it's Colonel North's handwriting.
Q And reading down, it says, "R. Miller", and I've
assumed that that applies to you. Are you aware of any other
R. Millers with whom Colonel North had dealings or conversa-
tions?
A No.
Q And at the top of the page is the notation, 19, N-
o-v, for November — and I'll represent to you that this came
from a 1985 notation. It states a time, I believe, as 11:30,
and as I can read it, I believe it says, "On hand, and acted
on . "
And then it lists information as to the movement,
or requested movement of certain amounts of money to various
recipients .
Are those recipients that you recognize?
A Yes, but I think you've misread it. I think it
says "Oliver North had and acted on." I think that's "O.N."
Q O.N. stands for Oliver North. Okay. And does this
notation refresh your recollection as to a conversation you
had with Colonel North back on November 19, 1985?
A This is the probably the conversation that you and
I just spoke of a moment ago.
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MR. DUDLEY: His question to you was whether it
refreshes your recollection-. He asked you a number of things
about it. He asked you the substance of it, and he asked you
the date of it, and I think he's asking if, after reviewing
that, you now have any further independent recollection
either of the substance of the conversation or whether it
actually took place on November 19th.
MR. KAPLAN: That's correct.
THE WITNESS: I can't confirm whether it was
November 19th. It seems to me that all these transfers are
transfers that we got instructions for pretty much all at
once, and this church account thing at the bottom is exactly
what I got for the transfer to the church account. So it's
probably all the same conversation.
BY MR. KAPLAN:
Q Okay. And toward the bottom of the top half of the
page, you see the notation that says, and I quote: "IBC,
dasji, 10 percent." Close quote.
A Right .
Q Is this note consistent with your general recollec-
tion as to Colonel North's approval of you and Mr. Gomez
charging 10 percent for your seirvices and professional risk in
your activities in connection with the contra funding, or
contra-assistance network?
A Yes.
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Q So if Colonel North were to say that he never
discussed a specific number with you, I take it that you
would say his recollection was probably wrong?
MR. DUDLEY: I object to asking witnesses to
conunent on testimony of other witnesses. He can tell you what
his recollection is, and from that you can draw your con-
clusions, but I don't think it's appropriate to ask one
witness whether another witness is right, or wrong.
BY MR. KAPLANS
Q Would it be inconsistent with your recollection, if
Colonel North testified that he didn't recall discussing a
specific number with you?
A I don't know what you mean by "specific number."
Q That is, 10 percent.
A If the question's 10 percent, then that would be
inconsistent.
Q But I take it that your recollection, independent
of Exhibit 15, and as refreshed or confirmed by Exhibit 15,
is that you specifically asked Colonel North for approval to
charge 10 percent of the money that was passed through IBC
for contra assistance?
A That's correct.
Q I take it that your recollection is that you
specifically received his approval for the 10 percent figure?
A Yes.
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[Brief recess . ]
MR. KAPLAN; Let's go back on the record.
BY MR. KAPLAN:
Q After receiving Colonel North's approval to begin
charging this 10 percent, when did you begin to deduct the 10
percent from the contra-assistance payments that were passing
through IBC?
A There was one $400,000 contribution where 10
percent was deducted, and then I think most of it was
deducted in the Grand Caymans, and some of it was done in
retroaction to the formation of World Affairs Counsellors.
Because they just didn't have time to get down there and form
World Affairs Counsellors, and so we had to do it in retrosp-
ect.
Q And when you say it was done in retrospect, did you
begin deducting the 10 percent as a paper matter, some time
prior to the formation of World Affairs Counsellors?
A Yes.
Q Do you recall when you started deducting the 10
percent as a paper matter?
A It was pretty close to this period in time.
Q Go ahead, if you've got something to add.
A No.
Q Do you recall the total amount of funds that were
deducted as part of this 10-percent charging of the contra-
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assistance payments?
A I don't have an exact figure for you but it's
somewhere around 250 to $300,000.
Q All right. Is it possible that the amount is
closer to 440 to $450,000?
A No.
[Witness and attorney consult.]
THE WITNESS: I know what your concern is. The
tail end of 1986, Colonel North gave us a directive to use
the remaining money in the account to pay legal fees as-
sociated with what we expected to be inclusion in some of the
matters that were pending down in the Federal court in Miami .
And in addition to that, we also sought reimburse-
ment for some specific items-, and in fact had to — for
instance — reimbursement Miller Communications for the 10,000
that went ^o^^^^^^H Things like that. And there was
generally a paper ledger kept on that.
BY MR. KAPLAN:
Q Did any funds make their way into World Affairs
Counsellors, that were not part of this 10-percent charge, or
commission?
A Any funds removed from IC, Inc. that were commis-
sion or reimbursement, that was the only way they went, was
into World Affairs Counsellors.
So that--
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A So it's the rule rather than the exception.
Q So that if 440 to $450,000 made its way into World
Affairs Counsellors, that might well represent the total
amounts that were deducted, or charged off as part of this
10-percent charge or commission.
A That's correct, although I think there are some
charges on this side of the Gulf of Mexico. I think there
are some charges in IBC accounts, at times, when, for
expediency reasons, money was transferred from IBC.
Q But if the records reflected that approximately 440
to $450,000 were deducted from IC, Inc., and placed into the
World Affairs Counsellors' account, you wouldn't dispute that
that amount is, if not all, at least very largely attributable
to the 10-percent charge, or commission that Colonel bkarth
approved back in November 1985. Is that correct?
A If you want me, I'll define large for you. I know
at least 100,000 of it was for legal fees at his direction,
and. I can't give you an exact figure, but several tens of
thousands more were for specific reimbursement items.
Q But nonetheless, the $100,000 for legal fees, I
take it, was money that was taken for the personal benefit of
you, or Mr. Gomez? I mean, the legal fees were at least
intended to be paid on behalf of you or Mr. Gomez's behalf,
is that right?
A That's correct.
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Q So it might not have been a part of the 10-percent
charge or commission that Colonel North approved, but
nonetheless all monies that went into World Affairs Counsel-
lors were monies that were ultimately used for the benefit of
either you or Mr. Gomez?
A No.
Q Tell me where I'm wrong, because we can clarify the
record on this, and move on.
A Well, if you are willing to accept that there were
reimbursement items in that money, then those items were not
for our benefit. They were simply reimbursement to us for
expenditures that we had to make.
Q What kinds of expenditures would those have been
reimbursement for?
like the to^^^^^^^^^^^^H that
had to come, out of Miller Communications. There was $10,000
in the cost of setting up the original corporations . There
was $100,000 in legal fees. I can't think of all of them,
off the top of my head.
Q The $100,000 in legal fees, for instance.
[Witness and attorney consult.)
BY MR. KAPLAN:
Q The $100,000 in legal fees, for instance, for whose
benefit was that money either spent, or intended to be spent?
A Well, to defend IBC. I mean, we fully expected the
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organization to come under legal attack.
Q And who were the two partners of IBC?
A Frank Gomez and Rich Miller.
MR. KAPLAN: I'm going to ask the reporter to mark
as Deposition Exhibit 16, again, a composite exhibit. I'm
not going to ask you any questions about the top letter
because I think you've covered that in your testimony.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 16. )
BY MR. KAPLAN:
Q The second page of the exhibit purports to be a
letter from David Piesing, at Cayhaven Corporate Services,
Limited, to you, dated May H, 1986. The letter is short,
and I'll just read it into the record.
It says, quote: "I refer to the verbal instructions
that you gave me during your trip here earlier in the month."
That is, that you gave to Mr. Piesing. "For some reason it
was overlooked, but we shall need written instructions from
you to automatically deduct 10 percent from any grants
received from this company, and to pay the 10 percent
deduction over to World Affairs Counsellors, Inc. as a
commission." Close quote. The rest are salutary words.
Can you identify this letter?
A Yeah. This was a letter from me to Mr. Piesing,
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referring to my instructions that from the beginning of World
Affairs Counsellors, any monies that came into IC, Inc.,
there was to be an automatic deduction of 10 percent, and
that money was to be deposited in World Affairs Counsellors.
Q And those instructions that you gave to Mr. Piesing
were simply the carrying out of an approval that Colonel
North had given to you back in November of 1985?
A Yes. But this was at the formation of World
Affairs Counsellors.
Q Right.
A The instructions were that any money that came,
once World Affairs Counsellors had been established — any
money from that date forward, that came into IC, Inc., there
was to be a 10 percent automatic deduction.
Q And the 10 percent that is mentioned in this letter
is not pulled out of thin air, it is the 10 percent charge,
or commission, or compensation that Colonel North approved
bacJc in November of 1985, and for which you had begun to
deduct as a paper matter some time shortly thereafter?
A That is correct.
Q Okay. Tell me why you felt entitled to receive the
10 percent that you requested from Colonel North.
A Well, I don't like the word "entitled." We had run
what I thought were extreme risks with the al-Masoudi
business. It had cost us personally, financially. It had
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taken up a tremendous amount of professional time. It was,
as any lawyer will tell you, or anybody who bills their time,
opportunities lost to make money with paying clients, and our
role with Colonel North seemed to be growing, and he seemed
to be asking us to do more all the time. And there was no
way for us to continue to do that unless we could start
compensating ourselves, since we were the primary wage-earners
for the rest of the employees at IBC .
Q On what basis did you think Colonel North was
authorized to approve your taking 10 percent of the funds?
A Just by virtue of who he was. He seemed to be in
control of the operation.
Q And was it your understanding that once the funds
for contra assistance left HEPL, that they basically were
under the complete discretion, or control of Colonel North?
A I viewed t.hem that way, yes.
Q And you testified earlier this morning, that there
was a time at which Mr. Channell told you that he was going
to begin to deduct 20 percent from the contributions intended
for contra assistance.
Was this about the same time that you obtained
Colonel North's approval to 10 percent as a charge for you
and Mr. Gomez?
A I don't think that's exactly what I said. I said I
recall one time when Mr. Channell told me he was going to
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deduct for his organization 20 percent from — and I think it
was a Barbara Newington contribution of — I think the total
was $1.2 million, or something. And —
Q Was that the Newington contribution to which you
testified on June 23rd?
A Yeah. And the subsequent, too, I think.
Q Other than the World Affairs Counsellors' payments,
did you receive any other benefits from your activities
involved in the contra-assistance network?
A Financial benefits?
Q Financial benefits.
A Well, we were paid fees by Mr. Channell for our
work on his programs, but, no.
Q Do you have knowledge of anybody else, other than
perhaps NEPL, as an entity, or Mr. Channell or Mr. Conrad,
through NEPL, deriving any benefit from the provision of
monetary assistance to the contras?
A Well, I think all their salaries were paid by NEPL,
so 'they, like any employee of an organization that undertakes
a prograun, they receive salaries from that organization.
Q Do you have any knowledge of anyone else receiving
any financial benefit from this contra-assistance network?
A Not other than what I've described to you in
previous transactions from IC, Inc. I don't have anybody
that comes readily to mind.
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Q Okay. What was your understanding as to the
intended purpose of the contra-assistance payments that were
made through IBC, or through IC, Inc.?
A The general purpose was for the provision of
assistance to the Nicaraguan resistance. It became clear,
early on in the relationship with Colonel North, that that
meant a fairly diverse group of people receiving assistance.
And in regards to the specific fundraising, we, at Mr.
Channell's direction, or request, tried to identify specific
items which people could raise, could give their money for.
These people who gave large sums wanted to do it
for something that was identifiable, and not for general
financial assistance.
Q And you testified Jaack on June 23rd, I believe,
that Mr. Channell focused on certain lethal supplies, in many
instances, as enticing donors to make contributions for
contra assistance, is that correct?
A I wouldn't accept the characterization, but I would
say that, initially, our fundraising was targeted at general
assistance. It began to incorporate things such as heavy-
lifting systems, Maule aircraft. The later period, Mr.
Channell began to raise money for specific weapons.
Q And anti-aircraft missiles?
A Anti-aircraft missiles, specifically.
Q And there were instances, as you testified, back on
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June 23rd, in which Colonel North supplied the information as
to what the contras ' needs were with respect to some of
these, both lethal and non-lethal supplies?
A That's correct.
Q And you also testified, back on June 23rd, that
Colonel North participated in some of the solicitations
intended for the purchase of these big-ticket items, both
lethal and non-lethal supplies, is that correct?
A Colonel North made presentations to people prior to
a solicitation from Mr. Channell. That's correct.
Q And part of his presentation, at times, included
references to lethal supplies as well as non-lethal supplies?
A In the single instance which I can remember, a
discussion of lethal supplies, I don't know whether Colonel
North was still in the room at the time, but I don't believe
he was .
Q Now to refresh your recollection, on June 23rd, you
testified in response to my questions as follows:
"Question. Did North describe the capability of
the shoulder-held surface-to-air missile that was in the file
folder to counteract the Hind helicopter?"
"Answer. He did refer to surface-to-air missiles,
but only generally. I don't think he specifically referred
to the one in the folder. "
"Question. When you said before that Colonel North
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referred briefly to the final folder that you prepared, how
did he refer to it?"
"Answer. I don't remember the specific conversa-
tion, but he was describing to Mrs. Newington how the Hind
helicopters had changed the battlefield tactics of the
resistance forces, breaking them into smaller units, not
allowing them to have large collections of soldiers. I also
had a copy of a New York Times piece on the Hind helicopter,
and as I remember, he used that far more prominently than he
used the folder."
'Question. Did Mrs. Newington ask Colonel North if
he knew where to obtain surface-to-air-missiles?"
"Answer. As I recall, her specific question was,
'And you know where to get these?', and he said, 'Yes, we
know . ' "
"Question. And did Colonel North quote any prices
to Mrs . Newington? "
"Answer. I don't recall."
MR. DUDLEY: Is that supposed to be inconsistent
with what he just said?
BY MR. KAPLAN:
Q Now does that refresh your recollection as to
whether Colonel North ever participated in the solicitation
of funds intended for the purchase of lethal supplies?
MR. DUDLEY: I object to this line of inquiry, and
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I don't think that's proper, either as refreshment of
recollection, or his impeachment, but I'll let him answer the
question .
It seems to me that there is absolutely no inconsis-
tency between that and what he just testified to.
THE WITNESS: And I guess what I'd ask you to do is
define your definition of "solicitation."
MR. DUDLEY: I think that's where you're falling
apart, is you're using the word differently.
THE WITNESS: I Just need to know what you
consider solicitation.
BY MR. KAPLAN:
Q Did Colonel North, in your presence, ever describe
to any contributor the contras ' needs for any particular
lethal supplies?
A In general terms, in conversation with Mrs.
Newington, he described surface-to-air missiles as devices to
shoot down Hind helicopters. «
Q And we've just read your testimony from June 23rd
in which you stated that he even told Mrs . Newington that he
knew where to get these missiles. Is that correct?
MR. DUDLEY: It is correct that you read that. Now
are you asking him if his testimony is correct?
MR. KAPLAN: Right. I mean if his testimony's
changed, I certainly want to know about it.
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THE WITNESS: No, no, it's not changed at all. In
fact I think I may have also said to you that "we" was a
euphemistic term that he used, as a convention in conversa-
tions with people. And one got the sense, when he said that,
that he was speaking more about the resistance than he was
about himself. So "we" was a collegial term which he used.
BY MR. KAPLAN:
Q That wasn't my question. My question was, is, in
your testimony on June 23rd you testified that Colonel North
told Mrs. Newington that he knew where these missiles could
be purchased.
My question is, is that testimony still accurate
today?
said yes.
MR. DUDLEY: And h« ' s answered that question. He
MR. KAPLAN: All right. And that's a yes or no.
MR. DUDLEY: He answered it.
MR. KAPLAN! And if he could answer it, I would
appreciate it.
MR. DUDLEY: Answer it again.
THE WITNESS: I'm not going to answer it yes or no
because it's not a yes or no answer. I mean, he used the
term yes, we know where to get them, and the "we" that he
used then was a euphemistic term which he'd used on other
occasions in my presence, and the sense that one had--and I'm
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sure Mrs. Newington had from the conversation — was that he
was speaking in a collegial .sense, and that he was as much
talking about the resistance as he was about his own know-
ledge.
BY MR. KAPLAN:
Q How can you testify as to what Mrs. Newington 's
understanding was of what Colonel North told her?
MR. DUDLEY: You've asked him questions all day
about what people understood, and when you want him to get
inside somebody's head, you're perfectly happy to ask it.
MR. KAPLAN: And he consistently has refused to
answer those questions .
MR. DUDLEY: Well, he said from contact —
MR. KAPLAN: On the few times that I have asked
him, and with specific reference to his knowledge--! have not
asked him what was in Mrs. Newington 's mind. I've asked him
a simple question which is whether his testimony on June 23rd
stands correct and true as of today.
And the answer is a yes or no answer. That's what
I'm asking for and that's what I would like from the witness.
MR. DUDLEY: :And he has given you that answer.
MR. KAPLAN: Would you please provide an answer to
that question, yes or no.
THE WITNESS: The answer to your question about my
testimony of June twenty--
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MR. KAPLAN: Third.
THE WITNESS: --third is yes.
MR. KAPLAN: Thank you.
I'm going to ask the reporter to mark as Deposition
Exhibit 17.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 17 . ]
MR. KAPLAN: It is the cover page plus the first
two pages of a report prepared by International Business
Communications and submitted to the Committees by your
counsel .
BY MR. KAPLAN:
Q I ask you to turn .to turn to page 3 of the exhibit.
It's the last page. The aecond-to-last paragraph from the
bottom states that some of the funds, as shown in the
attached materials, were deposited to the account of Lake
Resources, Inc. at Credit-Suisse Banque in Geneva, at the
request of Lt. Col. Oliver L. North.
And I'll skip the sentence and go down to the last
sentence in that paragraph which reads: "However, we were
assured by him at the time, that the funds were to be applied
solely for humanitarian assistance."
And my question is, did you believe that to be an
accurate statement when this report was written in February
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1987?
A Yeah, but I've got to tell you that I rue the day I
wrote those final five words.
Q And can you tell me why you rue that day.
A Because I should have said "were used for non-
lethal assistance" and that would have been a far more
accurate characterization.
Q Didn't you have an understanding, either from
Colonel North, or from Mr. Channell or Mr. Conrad, that at
least some of the monies solicited were intended for the
purchase of lethal supplies?
A Well, specifically, Mrs. Newington's contribution
was for surface-to-air missiles. Later, in that period of
time, that she gave the final contribution, the helicopters
seemed to be active, and there seemed to be little indication
that there were missiles on the ground to counteract them.
And the news accounts indicated that the number of
missiles that the resistance had was still low. And I raised
the issue to Colonel North, asking him in effect where were
the missiles, and he said they needed missiles, but they
needed these more. And he pulled out a brochure of radios,
some kind of secure, encrypted radios of some sort, and told
me that that money had been spent on radios .
So with the missiles removed from the matrix, I
felt quite comfortable with the characterization you see in
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this because the other money was used for the heavy lifting
and the air resupply operation.
Q Now you testified this morning that you plead
guilty to a one-count information, in part based on activities
in which NEPL's tax-exempt status was used for the solicita-
tion of money intended for the purchase of lethal supplies.
And is that a fair characterization of your
testimony this morning?
A Yes.
Q And am I mistaken in my belief that that charac-
terization— well, your testimony is somehow, or another,
inconsistent with the statement in this report about which we
were just talking?
MR. DUDLEY: I'm not going to let him answer a
question like that. Come on.
MR. KAPLAN « Are you going to instruct him not to
answer?
MR. DUDLEY: Yes.
MR. KAPLAN: Can I ask you to state for the record
the basis for your instruction.
MR. DUDLEY: Because the question of whether you
are correct in drawing inferences you want to draw about
consistencies is not something that he's in a position to
comment on.
MR. KAPLAN: That's fine. I'll rephrase the
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question.
BY MR. KAPLAN:
Q Is your testimony this morning consistent, the
statement in the report, that is. Deposition Exhibit 17,
about which we've just been talking?
A I don't think it's consistent or inconsistent.
This was a report to Mr. Channell on expenditures. The
information that you've asked me about and the guilty
proceeding that took place were not about expenditures. They
were about the means to raise the money for that effort, and
there's a diametric difference between the two.
And that I think you need to be clear on because
this report is an attempt to codify for Mr. Channell the
expenditures that we undertook. So that statement is about
expenditures, and with the surface-to-air missiles removed
from the matrix, there was nothing left, to my knowledge, of
a lethal sort.
Q I don't want to get into a semantic argument with
you, but in looking at the statement to which you're referr-
ing, I don't see the term "expenditures." What I see — and
we'll quote it again — is "We were assured by him--that is.
Colonel North — at the time, that the funds were to be applied
solely for humanitarian assistance." That is, were to be
applied.
And what I'm asking is, is that consistent with
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your testimony this morning, that you plead guilty to a one-
count information because of the fact that you considered
NEPL's tax exempt status to have been misused with respect to
solicitations intended for the purchase of lethal supplies.
MR. DUDLEY: Despite your disclaimer, Mr. Kaplan,
that question is absolutely nothing but argument. You can
make that argument, if you want to make that argiiment . If you
think they're inconsistent, fine.
MR. KAPLAN: I asked a question, and I would like an
answer to the question.
MR. DUDLEY: I object to the question.
MR. KAPLAN: All right. Could you please read the
question back?
MR. DUDLEY: It'll- take him a long time.
MR. KAPLAN: That's fine. I've got plenty of time.
REPORTER: "I don't want to get into a semantic
argument with you, but in looking at the statement to which
you.' re referring, I don't see the term expenditures. What I
see — and I will quote it again: 'We were assured by him' —
that is, Colonel North — 'at the time that the funds were to
be applied solely for humanitarian assistance.' That is,
'were to be applied' .
"And what I'm asking is is that consistent with your
testimony this morning? You plead guilty to a one-count
information because of the fact that you considered NEPL's
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tax exempt status to have been misused with respect to
solicitations intended for the purchase of lethal supplies."
MR. DUDLEY: I further object to the question on the
grounds that having had it read back to me, I don't understand
it. It's incomprehensible. And that it's been asked and
answered.
MR. KAPLAN: I'd press the question.
MR. MILLER: I think I've told you two things that
are a direct answer to your question, the first of which is I
rue the day I wrote those five words . And the second is that
again this was a report to Mr. Channell on expenditures, not
a report on the solicitation of items. And with those two
things, I think I have fully answered your question.
MR. KAPLAN: And i-s it your testimony today that the
statement which we have been focusing on is consistent with
your guilty plea in May of this year?
MR. DUDLEY: I'm not going to let him answer it a
third time. That's about all the answer you're going to get.
MR. KAPLAN: He hasn't answered it yet. You
instructed him not to answer it the last time.
MR. DUDLEY: I have not instructed him not to
answer it. I now am instructing him not to answer it a third
time.
MR. KAPLAN: On what basis? I'd like your basis
stated for the record.
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MR. DUDLEY: That it is abusive and repetitive.
MR. KAPLAN: I don't understand that to be a basis
for an instruction not to answer. I would direct the witness
to please answer the question.
MR. DUDLEY: You don't have the power to direct him
to do anything.
MR. KAPLAN: Let's go off the record.
BY Mr. KAPLAN:
Q Mr. Miller, can you explain to me what IBC's role
was in connection with various White House briefings that
were set up by NEPL contributors or potential contributors
throughout 1985 and 1986?
A We would contact the appropriate office in the
White House when Mr. Channel! determined that he wanted to
give a briefing to his contributors. We would provide the
basic background materials for the White House office that
would then make the memorandum recommending the meeting. We
provided suggested talking points, suggested schedules,
proposed dates, and associated audio-visual materials.
And we then worked with the NEPL organization to
coordinate schedules for arrival, clearance into the building,
escort to the room, and departing the building and reas-
sembling the group in whatever the location was that Mr.
Channell then had a subsequent meeting in.
Q With whom in the White House or the administration
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did you deal in coordinating these briefings on that side?
A Primarily the Office of Public Liaison, Linda
Chavez, Linas Kojelis, Pat Buchanan's office. And we kept
Colonel North informed--I at least kept Colonel North
infonned--of the briefings. And in some instances we asked
specifically for him as a briefer.
Q Who put you in touch with the Office of Public
Liaison in the White House?
A Nobody .
Q Did you know Linda Chavez?
A I had met her before, and I was known to the people
in the White House Public Liaison Office.
Q Did you know Mr. Kojelis?
A Not before a meeting with him in preparation for
one of these meetings .
Q Did Colonel North help to facilitate or coordinate
these White House briefings?
A I think the first one he — I can't recall specif-
ically, but I think the first one we asked directly of his
office for a briefing. And then subsequently we just simply
started doing it to the Office of Public Liaison. But I
think the first request went directly to his office.
Q Are you aware of memoranda that Colonel North would
write to the Office of Public Liaison or White House counsel
in connection with coordinating these briefings?
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A I don't have a specific recollection of any
documents like that right now.
Q What about one-on-one meetings between contributors
to NEPL and President Reagan?
A Well, in regards to Mrs. Newington, we provided to
the State Department specific items of Mrs. Newington 's past
political efforts on behalf of the president on the issue,
and that became ultimately a McFarlane memorandum to the
scheduling office. And I think the officer in charge--
actually the officer on that memorandum was probably Colonel
North.
Q And do you recall having drafted a memorandum for
Mr. McFarlane to send up the line requesting a presidential
one-on-one meeting or photo -opportunity with Mrs. Newington?
A I drafted a fair amount of the text of that
memorandum and a subsequent listing of her contributions.
Q What about other meetings that the president had
one-on-one or photo opportunities with NEPL contributors?
Did you have a role in coordinating those meetings or photo
opportunities?
A Well, my role was that — it was an IBC responsibility
to make those things happen.
Q And who at IBC was principally responsible to carry
out that IBC responsibility?
A Let's not get into another semantic argument. I
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was principally responsible, since I am and was the lead on
the client. I used in that endeavor David Fisner and Marty
Artiano and their contacts within the White House offices.
Q What about one-on-one meetings between NEPL
contributors and Colonel North? Did you have a role in
arranging those?
A Yes. In fact, initially I was the only one
responsible for arranging them until late '86, when Dan
Conrad attempted to insert himself in the process and then
also Mr. Channell. In both instances it was resisted by
Colonel North, and there may be a couple of meetings which
Mr. Channell then subsequently set up, but I'm not conversant
with the details.
Q In what period would that have been in which
Channell or Conrad set up meetings directly with North for
NEPL contributors?
A It would have to be in late '86.
Q Late '86.
A Yeah. Okay.
Q Is it your understanding that every one-on-one
between Colonel North and NEPL contributors prior to late '86
was arranged by you?
A Yes.
Q Just off the top of your head — I'm not asking you
to give me an exhaustive list — what NEPL contributors do you
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recall having met one-on-one with Colonel North?
A Barbara Newington, Fred Sacher, David and Paula
Wurm, Edmund Brandon, Dr. Marietta Keywitz, Barbara Christian
Bullitt, Thomas Claggett, Patty Beck. That's all I can
remember right now.
Q Were you involved in arranging the one-on-one
meeting that Colonel North had in March of 1986 with a
William O'Boyle?
A Yes. It was one, as I recall, of a series of
meetings. And the initial meeting was one of that series,
and I'm the one that arranged the series with Fawn on Colonel
North's schedule.
Q Did you tend to arrange one-on-one meetings with
Colonel North following the briefings to which we have
referred?
A I'll accept the word "tend", because generally what
would happen is that after Mr. Channell had the day's program
and the evening dinner that it was associated with the
Central American Freedom Program, he would have then identi-
fied anywhere from one to six or seven people who wanted to
participate in the assistance effort. And those were the
individuals that were then scheduled to see Colonel North.
There were, however, other meetings which had
nothing to do with events here in Washington, more general
Central American freedom program briefings, such as the
mini (If^nirifi-n
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meeting with Mrs. Newington in Connecticut.
Q You're talking about the weekend trip, okay. We'll
get to that in a minute.
Back on June 2 3rd, where you covered your knowledge
of solicitations of Mr. Ramsey and Mrs. Newington, and then
earlier today we covered a couple of additional notes about
the Ramsey solicitation in June of '85, and the subsequent
mailgram that went out to Mr. Channell.
In connection with the Newington solicitation in
November of 1985, about which you previously testified, I am
going to ask the reporter to mark as Exhibit 18 a copy of a
set of handwritten notes, and ask you if you can identify
those notes?
A Yes, they are ray handwritten notes.
(Exhibit No. 18 was marked for
identification. )
BY MR. KAPLAN:
. Q Were these notes written in preparation for the
solicitation of Mrs. Newington?
A Yes.
Q Can you explain the circumstances of the context in
which these notes were written?
A These were the precise things that Spitz Channell
wanted Colonel North to say to Mrs. Newington.
Q The amount that's listed at the top of the page is
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$1.2, is that correct?
A Correct.
Q Was that the amount for which you understood Mrs .
Newington was going to be solicited?
A Yes.
Q Was she in fact solicited for that amount?
A I think at this point she had actually already been
solicited to some degree, and I think she had made this
commitment to Mr. Channell, or was about to make this
commitment to Mr. Channell.
(Witness and attorney consult.)
THE WITNESS: There's a squiggle line down through
the middle of the page that goes to November 1, January 1,
February 1. And the reason . I said what 1 just said to you is
I don't recall whether that was written at the same time
these other items were written down.
BY MR. KAPLAN:
Q I see.
A And that may well be the reflection of a later
conversation with Mr. Channell.
Q So it could well be that the actual amount and the
breakdown of $400 times three was written sometime after this
solicitation to which you testified on June 23rd and referred
to earlier today?
A It's possible that those three items listed as
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November 1, January 1, and February 1, each for $400,000, may
have been written at a different time.
Q When we say a different time, we're talking about a
different time from the notes that are on the bottom half of
the page?
A Correct .
I think you only used the word "possible, " and I
want your record to reflect that. I'm really not that clear.
MR. DUDLEY: I think you misspoke. You charac-
terized that word as November 1, when I believe the word is
"now. "
BY MR. KAPLAN:
Q Can you read into the record, Mr. Miller, the
handwriting on the bottom o£ the page that starts with the
word "green"?
A It's "Green dash now working a year on this
program. "
Second item, "most secure person we know in the
U.S."
Third item, "We are asking you to take on a project
that requires your kind of person."
Q Now, do you recall the circumstances under the
contact in which those notes were written?
A Those were elements of a conversation that Mr.
Channell hoped Colonel North would have with Mrs. Newington.
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Q And this conversation between you and Channell took
place prior to the Newington solicitation?
A Correct.
Q I take it the green refers to Colonel North?
A Correct.
Q Did you relay this proposed pitch, if you will, to
North?
A I don't recall relaying it to him, and I don't
recall him using it.
Q Is it possible that you relayed this pitch to North
in a bit softened form?
A That's possible. But again I don't have a specific
recollection of a conversation with him.
Q You testified a moment ago as to a weekend trip to
Mrs. Newington' s.
Do you recall when that trip took place?
A Not specifically. I remember it was chilly, and I
donit think there were a lot of leaves on the trees. That's
about the best I can do to give you a specific time. I don't
have it in my calendar.
Q Who accompanied you on that trip?
A Colonel North, his wife Betsy, his son, and his
youngest daughter.
Q How did you make the travel to Mrs. Newington 's in
Connecticut?
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A We went by chartered jet.
Q Who paid for the jet?
A I assumed it was Mrs. Newington or Mr. Channell, I
don't know which.
Q What was the purpose of that visit?
A It was billed to both Colonel North and myself as a
picnic at Mrs. Newington's, a chance for Colonel North to get
away. He was, by everybody who saw him's account, fairly
frazzled and exhausted, and it was billed as an opportunity
for him to relax and be with his wife and children.
Q Was Mrs. Newington solicited funds during that
weekend?
A Yes.
Q By whom?
A By Mr. Channell.
Q Was that solicitation in Colonel North's presence?
A It began somewhat in Colonel North's presence.
_ Q Do you want to just describe it?
A Yes . We had been there a day . I think we ' d
finished — we had dinner the night before and slept the
night and had breakfast the next morning. And Ollie was
sitting out on the porch area by the pool, just kind of
relaxing. And Spitz asked me to come with. and Barbara
Newington over to the place where Colonel North was sitting.
And he asked Colonel North to give Barbara a description of
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the way things were going on the ground in Nicaragua.
I got the feeling that he was somewhat disturbed by
having to do that. He didn't really think that to be the
purpose of his being there. But he agreed to do it, and
described to her the general situation on the ground for the
resistance fighters.
And Spitz then asked Ollie what it is going to take
for the next — I've forgotten how many months — how much
does it cost a month to keep their operation going? And
Ollie 's response was $2 million. And at that point he was
beginning to be agitated, and he simply got up and kind of
walked away. It was clear to me that he did not want to be
put in the position he had just been put in.
And then Mr. Channell asked Barbara Newington to
please help. And she agreed.
Q Tell me what you know about a solicitation of
Nelson Bunker Hunt that occurred sometime in early September
1985.
A Mr. Channell had gotten a contribution from Mr.
Hunt somewhere in the neighborhood of $475,000. But it was a
little unusual. It had come as a 2 30 some thousand dollar
contribution, and then a like amount as a loan. And the way
it was left with Mr. Hunt was that that was a loan so Mr.
Channell could use that money while he raised money from
other people to repay it.
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Mr. Channell didn't believe in spending money he
didn't have in the bank, and he didn't believe in going into
debt in fund raising so he refused to spend that money and he
kept it in the bank.
Then Mr. Channell asked that I call Colonel North
and ask him to call Bunker Hunt, and to explain to him that
the 22 hundred and 30 some thousand dollars had gotten where
it was supposed to go, and that specifically that the
supplies were getting to the Nicaraguan resistance.
I think that Mr. Hunt was under the impression that
he had given money for aerial supply operations.
Q Were you aware that Colonel North had flown to
Dallas to meet with Mr. Hunt sometime prior to Mr. Hunt's
having committed the $475, OCM) as a part loan, part contribu-
tion to NEPL7
A I'm aware that Spitz Channell and Ollie North met
with Mr. Hunt at a dinner in Dallas that was for resistance
figures from around the world. I've forgotten who the actual
sponsor was, but it was a political event which several
hundred people went.
Q Are you aware that at or around that time Channell
solicited Hunt for the money that resulted in the 237.5
contribution and the 237.5 loan?
A Until you mentioned it just now, I had never put
two and two together, but you're probably right.
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Q I am going to show you a copy of what has already
been marked as Deposition Exhibit No. 6. It's a note which
you've testified before is dated 9/18/85, that is September
18, 1985.
The number two item on that note says "Green is to
call Bunker. "
To the best of your recollection, is that the phone
call to which you were just referring?
A Yes.
Q And No. 4 on that note says "Reagan thank you."
Does that refer to the contribution and loan that
you understood Hunt to have made?
A No. I think that's a thank you to Spitz Channell.
Q Okay. No. 3 on the list, which is crossed out,
says "Bunker with RR call or" — and I can't read the last —
"call or visit," I think it says.
Do you recall what the source of that note is and
why it's crossed out?
A These are all things that Mr. Channell wanted. He
wanted Bunker to have a meeting with the President or call
from the President.
Q Did you take any action to get Mr. Hunt a meeting
with the President or a call from the President?
A On this specific request, I don't think I took any
action because there's a line drawn through it. And that
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usually means that I just — it's something out of hand or,
for one reason or another, I just didn't do it.
Q And then you testified that Nos . 7, 8 and 9 were
probably written at some time different than Nos. 1 through 6
on that note.
A That's correct.
Q And 7, 8 and 9 —
A They're in different colored ink even on the
original .
Q And 7, 8 and 9 were written in connection with a
phone conversation I believe that you were having with
Colonel North, is that correct?
A I don't think it was a phone conversation. It was
a conversation nonetheless. -
Q Was it a meeting, a face-to-face meeting?
A It may have been, but it was a conversation.
Q Okay. I believe it is also accurate to say that
the. entries 7 and 8, one of which refers to weapons, and the
other which refers to Maule aircraft, I believe, were, at
least to your knowledge, items provided to you by North with
his knowledge that those items likely would be used by
Channell in fund raising for the contras?
I didn't mean to confuse you there. I'm just
trying to sum up your prior testimony without having to take
you through it again.
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A Well, let me give it to you just very short and
sweet .
Those were items that I discussed with Colonel
North when Mr. Channell was trying to identify big ticket
items for which he could raise funds.
Q Colonel North understood that these items and these
prices would be used by Channell in connection with his fund
raising efforts on behalf of the contras, is that correct?
A These were items in a discussion about that. I
don't know that we ever came, — I know that the Maule became
something which we raised money for. We never raised 415,000
specifically for weapons, C4s and M17s.
Q But, nonetheless, again I'm not trying to trick
you. I 'think you testified -about this before.
Nonetheless, when North provided you with these big
ticket items, he understood the reason why he was giving you
big ticket items was for Channell to use in fund raising?
- A That's correct.
Q Mr. Miller, do you recall —
MR. DUDLEY: Can we go off the record a minute?
MR. KAPLAN: Sure.
(Brief discussion off the record.)
MR. DUDLEY: With respect to the basis of the
discussion off the record, we have agreed that, with respect
to Deposition Exhibit 6, which is a document produced by us
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in response to subpoena, our date stamp number is 004375, and
the Committee's document identification number RM000971, that
that portion of that page, after the first nine items, and
beginning 9/20/85, is material that relates to clients of IBC
other than anything — it had nothing to do with this
investigation, and that we will supply the Committee with a
redacted version of this document for purposes of attachment
to the deposition and for purposes of the Committee's
permanent records . And we had intended to redact that
material at the time of production.
MR. KAPLAN: And I will just state for the record
that on behalf of the Senate Committee, and I am sure I speak
for Mr. Fryman on behalf of the House Committee, we will make
all best efforts to make sure that the properly redacted
version does indeed replace the version with which we've been
supplied to date. I only caution that we can't guarantee
every single copy that might have been made in the process of
the- months of investigation that have preceded after produc-
tion of this document .
MR. DUDLEY: I understand that, but I appreciate
your willing to supply right now.
BY MR. KAPLANS
Q Mr. Miller, do you recall a time in January of 1986
when Mr. Channell returned an intended loan^of $237,500 to
Bunker Hunt?
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A Actually I think Bunker Hunt forgave the loan. So,
in effect, he made two contributions.
Q That's your understanding?
A Right.
Q How did you arrive at that understanding?
A I believe Mr. Channell told me so.
Q And do you recall a phone conversation with Colonel
North in early January in which you told him that Bunker Hunt
promised $237,000?
A I don't recall it, but it's entirely possible. I'm
sure I reported the results of his phone call to him.
Q This would have been several months after that
phone call I take it?
A I don't think any -of this moved very quickly. I
think it took a fairly long period of time.
Q Did you ever participate in obtaining a letter from
the President to be sent to Mr. Hunt thanking him for his
support without expressly mentioning the money contribution?
A I believe Mr. Hunt was one of the individuals who
got letters, general thank you letters for their participation
in the Central American Freedom Program. And those names
would have been provided to me by Mr. Channell.
Q How would you go about obtaining letters or making
sure the letters got sent from the President to the various
NEPL contributors as. Channell requested?
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A We would draft a potential letter, submit the names
generally to Colonel North. As you were asking your question,
I was trying to remember whether there was anybody else that
we sent requests to when we may have sent requests to the
President's special message list. There's an office that's
associated with the White House that handles these types of
letters of thank you to people.
Q Was North generally the switching point for these
letters from the President to the NEPL contributors?
A Yes.
Q Did you also, on a number of occasions, draft thank
you letters from North to those same or other NEPL con-
tributors?
A Yes .
Q Did Mr. Fischer or Mr. Artiano play a role in
obtaining letters from the President to NEPL contributors?
A I don't recall any specific instances when they did.
Q So it was all done through you and through Colonel
North, and then whatever else had to be done in order to have
the President sign the letter and send it to a contributor?
A That's correct.
Q Do you recall attending any NEPL dinners in which
Mr. Channell showed to NEPL contributor or potential con-
tributors letters he had received from President Reagan
thanking him for his support?
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Q Was that something that he generally did?
A Yes. Not just at dinners but in solicitations.
Q Is it fair to say that Channell used these letters
for fund raising purposes?
A I think it's legitimate to say that Channel used
them as evidence of his past programs. They were all
retrospective letters thanking him for past programs which he
had funded and executed.
Q Then he did use the letters at these dinners that
often would follow the briefings and, as you just mentioned,
in solicitations of particular individuals?
A Well, what he would do is he would take the letters
and make them part of a general package of information that
the people would have at their seats . And the package would
also contain documents about the Soviet-Cuban military
buildup, of terrorism activity by the Nicaraguans, a map of
Nicaragua. In one instance, we put a book from a New York
Times reporter in there.
But he would put these letters that were thank yous
for past programs in the same packages.
Q How did Channell come by these letters? Was it the
same process by which you worked getting letters to NEPL
contributors from the President? Would Channell make a
request to you for a thank you letter from the President and
264
UNCLASSIFIED
261
1 you would then convey that to North who would then work it up
2 through the White House channels and eventually get the
3 letter issued?
4 A There were a couple of instances in which it was
5 done that way. But often it was just because somebody at the
6 White House properly triggered it, the Political Office saw
7 the ads on television, or Channell was asked to come and
8 participate in a meeting at the White House in which people
9 were asked to help on the issue, that type of thing.
10 Q Is it possible that North would have triggered
11 thank you letters to Channell or to other individuals without
12 your knowledge?
13 A Sure.
14 Q Tell me what you know about the solicitation of Mr.
15 0' Boyle in late March of 1986.
16 A I know very little about it. All I know is that he
17 was brought down by Jane McLaughlin, and that his first
18 contribution was $100,000. That's all I know.
19 Q Is it possible that his first contribution was
20 $130,000?
21 A Possible. I think there's a commission paid to
22 somebody in there. I'm not sure.
2 3 Q Did you arrange the one on one meeting between
24 0' Boyle and North or the series of meetings?
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several meetings that took place over the course of an
evening and the next morning. I don't want to say evening or
next morning. Anyway, after the next day after Channell's
Central American Freedom Program briefing and dinner that
evening, there were meetings with Colonel North one on one
with people who wanted to provide assistance money. And he
was one of them I think.
Q When was that meeting arranged if you can recall?
A I don't recall specifically.
Q Was it prior to the briefing?
A I don't think so. I think it was after the
briefing.
Q Do you think it was at the dinner after the
briefing?
A I think it was after the dinner after the briefing.
Q Who asked you to arrange that meeting?
A Channel 1.
Q Channell did.
Tell us what you know about the solicitation of
Mrs. Garwood that occurred in April of 1986, if you know
anything?
A I don't know anything about it. When was it?
Q April of 1986.
A I'm not familiar with it.
I can't say that I don't know anything about it. I
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think Mr. Channell told me that Mrs. Newington, or Mrs.
Garwood was giving a million something, I think it was a
million and a half. And I recall that I got a phone call
from him about it, but I don't recall much more than that.
MR. MILLER: I was not there. I was here in
Washington.
BY MR. KAPLAN:
Q I think when we went off the record, we were in the
middle of an answer that you were giving. I had asked you
what your knowledge was of an April 1986 solicitation of Mrs.
Garwood .
A I think I had finished the answer.
Q Do you recall anything about the solicitation of a
Mr. C. Thomas Claggett?
A Yes . I sat in the room with Colonel North and
Spitz Channell and somebody else. I can't remember who the
somebody else is. It may have been Chris Littledale or Chris
Smith. And Colonel North described to them what was going on
down in Nicaragua in terms of battlefield activities. I
think he even got up and showed them a map.
I don't think I stayed for the whole meeting.
Either that, or according to the press reports, Mr. Claggett
and I went to two different meetings.
Q Did you arrange the meeting between Colonel North
and Mr. Claggett?
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A Yes.
Q Were weapons discussed in your presence at that
meeting?
A I don't recall weapons being discussed at that
meeting.
Q Let's go back and clarify the record on one point.
It seems that you and I have a different view semantically of
the word solicitation and that you view solicitation in what
may well be a proper fashion — the dictionary definition of
when did someone ask for money. And I have been speaking of
the term solicitation as sort the overall transaction without
any particular purpose other than as a shorthand.
I think that's what gave rise to the difference we
had as to any testimony you -gave today was supportive of or
possibly inconsistent with testimony you gave back on June 23
with respect to the transaction by which Mrs . Newington
eventually was solicited for funds for some lethal supplies.
Is it fair to say that you stand by the testimony
that I read to you from June 2 3?
A Yes.
Q And is it fair to say that Colonel North was
present in the room and indeed participated in a discussion
with Mrs. Newington about lethal supplies that were needed by
the contras?
Yes.
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Q Just to make the record complete, as part of your
standing by your testimony on June 23, in that testimony I
believe you stated that you didn't recall specifically
whether Colonel North was in the room when Channel 1 asked
Mrs. Newington for money to provide those supplies. Is that
correct?
A That is correct.
Q And I believe you further testified in that regard
that if he was absent from the room, that would not have been
unusual because it was his general practice to leave the room
before Channell actually asked a contributor to pay over
funds .
A That's correct.
Q Then we are in complete agreement as to what your
testimony was then and is now. I apologize if my use of the
term solicitation threw you off in any way.
A No apology necessary.
Q Thank you.
Are you aware of any arms list or purchase list other
than the big-ticket items list that you have described before
that was used by Channell in his solicitation or fundraising
from certain individuals?
[Witness and attorney consult and brief recess]
MR. DUDLEY: Could we just have the question again
to make sure we got it dn-iljind?
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<Pending question read back>
MR. MILLER: Yes.
MR. KAPLAN! Could you describe the list?
MR. MILLER; I was shown by the independent counsel
some time in May — early May — a list that Mr. Channel 1 had
used to solicit John Ramsey for a contribution, and it was a
Spanish-language list of captured armaments captured by the
Nicaraguan resistance forces. And Mr. Channell in his letter
to Mr. Ramsey held it out as a list provided to him by Adolf o
Calero of weapons needs.
That was the first time I saw it used in that
context. I am quite familiar with the list that came up of
captured articles. It is one way that the Nicaraguans report
to the media and Congress and the administration about their
level of battlefield success.
MR. KAPLAN: I'm going to ask the reporter to mark
as Exhibit 19 a copy of a handwritten document that was
provided to us by your counsel .
[The document referred to was
marked for identification as
Miller Deposition Exhibit No.
19.]
BY MR. KAPALN:
Q I ask you if you recognize that handwriting.
A Yes. It's my handwriting.
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Q Do you recall the circumstances under which these
notes were made?
A They were to-do items. I think most of them are
reflective — maybe all of them — but at least most of them are
reflective of a conversation with Channell or Dan Conrad, and
I'm not sure which one.
Q You see item number one in this note which is dated
February 5, 1986 reads, "Ollie's new purchase list".
A Yes .
Q Do you recall what that notation refers to?
A Yeah. I think that refers to the fact that Mr.
Channell felt that he had fulfilled the big-ticket item list
that had been provided to him and that there was a need for a
new purchase list.
Q Did you ever speak to North to provide you with a
new purchase list?
A I don't at the moment recall whether I had a
spefific conversation with him, but I don't think we ever
produced a new purchase list.
Q Did North ever provide you items along the lines of
the earlier exhibit we discussed for Channell 's use in
fundraising?
A Did Colonel North ever provide —
Q Did he ever provide you with prices and items
subsequent to this date that Channell couid,use in his
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f undraising?
A Not subsequent to.
Q Just very quickly--numbers four and five refer to a
dinner for Newington "... and Ollie at the Newington/RR
meeting. " Do you know what those notes refer to?
A Spitz wanted to have a dinner for Mrs. Newington
honoring Mrs. Newington, and he wanted Colonel North to
attend Mrs. Newington 's meeting with the president.
Q Did that meeting come about?
A Mrs. Newington had two meetings with the president.
Q One, I take it, was in November of 1985.
A Yes, I believe that's correct.
Q And was the other one subsequent to this note?
A I believe so, yes.-
Q And was it set up pursuant to Channell's request as
reflected by this note?
A It was set up pursuant to Channell's request. I'm
not sure if this note is reflective of that. It simply--
you're right. It's reflective of it. He had requested a
meeting with Mrs. Newington and the president.
Q Just to make sure I didn't miss anything, these
notes — that is. Exhibit 19 — were taken from a conversation
that you had with Channell.
A Correct.
Q What knowledge, if any, did you have of a project at
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NEPL that was called the "toys project"?
A Aside from the subsequent Jane McLaughlin charge
and Channell public response to it, I don't have any other
knowledge of it.
Q So you learned about the toys account at the same
time that the reading public learned about it--the "toys
project" .
A Yeah, but again I would think — yes.
Q Did you learn about the "toys project" from the
press?
A I learned eUx>ut the use of the words "toys project"
or "toys fund" or whatever from the press, but I was aware of
a similar activity to it — an activity similar to it earlier.
And I had heard the word before.
Q So that during the time that you were engaged in
contra .ssistance with NEPL and with Colonel North, you were
aware that NEPL had a project which they designated funds
intended for the purchase of weaponry or lethal supplies. Is
that what you're saying?
A No, that's not what I'm saying at all. I knew that
there was an effort around Christmas of 1985 by Mr. Channell
to raise money specifically for Christmas for the Nicaraguan
freedom fighters' feunilies.
Q Did you have any awareness that there was a project
that was called "toys" within NEPL that was considered by
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people at NEPL to be the project to which contributions
intended for the purchase of lethal supplies would be
designated?
A No.
Q When was the Institute for North-South Issues
created?
A I believe it was started in February of 1984.
Q 1984?
A I believe that's correct.
Q Why was INSI created?
A It was Frank's belief — Frank Gomez's belief — that
there needed to be an organization that encouraged cultural
and educational exchange between the northern and southern
hemispheres in that you have- the wealthier nations — -the have
and have-not nations, the third world and the developed world.
Q When did Gomez leave the State Department?
A Well, I don't know when his actual retirement date
wasj but I think it was like the last week in January--formal
retirement was then.
Q Was INSI one of the first projects in which Gomez
engaged when he left the State Department?
A He set it up fairly soon after leaving the State
Department, but it didn't even begin any activities until
much later.
Q Were you involved in the formation of INSI?
UMP' Agginrn
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A I was the treasurer at the formation of INSI.
Q Did you hold any other position in INSI at any
other time during its existence?
A I don't think so.
Q Do you recall when INSI received a letter of
determination of tax exempt status from the Internal Revenue
Service?
A All I recall is it took a very long time to receive
it. There was some wrangling between our attorneys and the
Service, and it seemed to all hinge on procedural matters and
not substantive matters. But it ultimately was resolved, and
we got--we actually got a more restrictive but a better
status from a tax point of view than we expected originally.
Q Whose idea was INSI?
A Frank's.
Q Do you recall a conversation with Colonel North on
February 1, 1985 in which you and he discussed INSI?
A February 1 of '85?
Q Yes.
A We probably had a discussion at that point.
Q Was INSI an idea of Mr. Gomez's before he actually
retired from the State Department?
A Are you saying February of '84?
Q No, February of '85.
MR. DUDLEY: I don't think he's asking with
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reference to a date.
MR. MILLER: I don't know. I think it was, but I'm
not sure. I think you should ask him.
BY MR. KAPLAN:
Q Do you recall the context in which you would have--
in which you did discuss with Colonel North INSI in early
February of 1985?
A My problem is that he pegged it to a specific date,
and I can recall a couple of conversations with him about
INSI, and I'm not sure exactly what the time frame was.
Q Why don't you just tell me about those conversa-
tions .
A He or Bob Earl — I've forgotten which — called one
time and asked for a list of- non-profit organizations
associated with I think the quote was "our side of the
issue" — supporting the president on Nicaragua. And I
produced that list for them.
And I would say that was some time prior to June of
1985, because it only lists the American Conservative Trust
and doesn't list NEPL. And INSI was on that list.
I then also at another time was asked by Colonel
North to get in touch with Roy Godson — that Godson had a
contributor who wanted to make a contribution to the resis-
tance. I went and met with Mr. Godson.
He informed me that this individual did not want to
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give money to Spitz Channell . He used his name specifically.
And that this individual was looking to provide money for
political activities.
I was left with the distinct impression that the
individual was interested in supporting the political
activities of the resistance.
Q I'll get to that transaction in a moment. I want
to stick with early 1985.
Do you know why or were you told why Earl or North
asked for this list of tax exempt organizations that were "on
your side"?
A Maybe, but I don't recall now what the reason was.
Q Who is Jimmy Lyons?
A I don't really know. I know he's a very wealthu
individual who is associated with the conservative movement.
That's about all I know about him.
Q Did you have discussions with Colonel North in
early 1985 in which money — in which the idea of conveying
money for contra assistance through INSI was discussed?
A In what time frame?
Q Early 1985.
A Early 1985. We may have, in reference to--we may
have discussed it in reference to al-Masoudi.
Q This would have been — I'm talking about a period
prior to the al-Masoudi referral.
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A I don't recall any specific conversations about
using it as a conduit for funds to the Nicaraguan resistance.
I remember a general impression that he had that it could be
used, and I was required later to dissuade him on that. But
I don't remember the specifics of how he came to understand
that.
Q Why was North told about INSI and its tax exempt
status? Why did you bring that up in conversation with him?
Why would you have brought that up in conversation with him?
A I don't know. I mean, I don't remember the
conversation, so I don't recall any elements of it.
Q Do you know a Warren Hendricks?
A Yes.
Q Who is Warren Hendricks?
A Warren Hendricks works for Clement Stone.
Q Do you recall a conversation with Colonel North in
which the names of Warren Hendricks and Clement Stone were
discussed?
A I talked to Warren Hendricks on one occasion.
MR. DUDLEY: Don't think out loud; answer his
question.
MR. MILLER: It's specific to his question, but I
haven't recalled it before right now.
He was being asked for money, and he turned it
down. He didn't even talk to Clement Stone about it. He —
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BY MR. KAPLAN:
Q What was the purpose of the request for the money,
if you recall?
A I can't recall.
Q Who asked him for the money?
A I did. He may have talked to Warren Hendricks.
Q Who is he?
A North may have talked to him. I'm sorry. I'm
recalling this for the first time, so it's sketchy, at best.
It's a long process, as you're aware.
Q What was the purpose of the money — contra assis-
tance?
A It had something to do with the Nicaraguan issue,
as I recall.
Q And you mentioned earlier that there was a time
when you had to dissuade North from the idea that INSI would
be used as part of a contra funding network. Do you want to
tell us a bit about that?
A After the second transaction through INSI, there
were two — the first for $100,000, the second for $60,000. I
told him that we simply wouldn't do it anymore.
Q Again, back to the time frame in early 1985--was
there a conversation with North that you recall in which the
idea was discussed of using INSI to funnel money to the
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contras?
A Again, I don't have a specific recollection of a
conversation.
Q When Mr. Hendricks was asked for money by you, was
he asked to contribute to XNSI?
A I can't remember what the substance of the contribu-
tion was. This may all be about the time of the Nicaraguan
refugee fund dinner and when it was being put together,
because it really got started in January. I think the
meeting I attended was in late January, and it took until
February or March for the dinner to come off.
Q . Would money for the Nicaraguan refugee fund dinner
have been solicited for contribution to INSI?
A It shouldn't have been.
Q You have mentioned earlier in your testimony a
$100,000 contribution that was made to INSI from the Heritage
Foundation. I'm going to ask the reporter to mark as
Deposition Exhibit 20 a copy of what purports to be a letter
to you from an Edwin J. Feulner, president of the Heritage
Foundation, dated October 15, 1985.
[The document referred to was
marked for identification as
Miller Deposition Exhibit No.
20.]
BY MR. KAPLAN:
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Q Do you recognize this letter?
A Yes.
Q Is this a letter which evidences the $100,000
contribution from the Heritage Foundation to the INSI, about
which you just testified?
A Yes.
Q Can you tell us the circumstances under which this
$100,000 was contributed to INSI?
A Well, as I testified earlier, I was contacted by
Colonel North, who asked me to get in touch with Roy Godson.
I called Mr. Godson and went to see him in his office. He
told me that he had a contributor that wanted to make a very
large contribution. I suggested that he give him Mr.
Channell's organization name- — allowed to make the contribution
to Mr. Channell's organization.
He told me that the individual was not interested in
making a contribution to Spitz Channell's organization and
thaJt he hoped there would be some other way the transaction
could be handled. I told him I thought that was possible but
that I would have to get back to him.
I went back and discussed it with Frank Gomez. I told
Frank I didn't think it was reasonable for the foundation to
be risked without some compensation to the foundation for the
risk associated with it.
Q When you say the foundation, what are you referring
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A Institute for North-South Issues.
And Frank agreed. I then went to see Colonel North and
told him that INSI could accept the contribution but that it
would charge a 20-percent overhead charge for administering
the grant. He agreed that that was acceptable.
I went back to Mr. Godson and told him that his
donor could make the contribution payable to the Institute for
North-South Issues. I gave him the name and the address and
so forth, and the next thing I got was a request for a
proposal from the Heritage Foundation.
Q Did you understand the request for a proposal to be
connected to the Godson donor?
A Yes. Not prior to- receiving it, however.
Q How did you make the connection between the
Heritage Foundation request for a proposal and the Godson
offer of a contributor?
A Same dollar amount, same time period, same terms of
reference .
Q Did you speak to Mr. Godson?
A Probably, but I don't remember specifically after
that.
Q Did you know Mr. Godson before North referred you
to him?
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Q And did you subsequently make a proposal to the
Heritage Foundation?
A I did.
Q Under the name of INSI?
A Correct.
Q And did the Heritage Foundation subsequently
approve your proposal?
A Yes.
Q That approval, I take it, resulted in the letter
and contribution that's evidenced by Exhibit 20.
A That's correct.
Q What did INSI do with the $100,000 contribution?
A It was transferred to IC, Inc. Well, $80,000 was
transferred to IC, Inc.; $20-, 000 stayed in INSI.
Q What ultimately happened to that $20,000?
A Well, it went into the general account at IC, Inc.
and was used for efforts that Colonel North —
MR. DUDLEY: He asked about the $20,000.
MR. MILLER: Oh, the $20,000.
MR. KAPLAN: The $20,000.
MR. MILLER: It was used for general administra-
tion— salary for the executive director, paper, xeroxing, and
all the other things associated with all of that.
BY MR. KAPLAN:
Q Who was the executive director?
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A At that point, Henry Quintero.
Q And the $80,000, I take it, went into the IC, Inc.
account and was disbursed pursuant to instructions by Colonel
North.
A Correct.
MR. ICAPLAN: I'm going to ask that the reporter mark as
Exhibit 21 a copy of what purports to be a Form 990 that was
filed for the tax year 1985 by INSI.
[The document referred to was
marked for identification as
Miller Deposition Exhibit No.
21.]
BY MR. KAPLAN:
Q I'm going to ask you, Mr. Miller, if you can
identify this Form 990.
A Yes. This is our Form 990 filed for the tax year
1985.
Q And is this Form 990 signed by you on the last page'
A Yes, it is.
Q It's signed by you in the capacity of treasurer?
A Yes.
Q I'm going to direct your attention to part 3. A. on
page two of Exhibit 21 and ask you whether the $80,000 listed
on the right-hand column of part 3. A. is the $80,000 that was
transferred to IC, Inc. from INSI as a result of the $100,000
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from the Heritage Foundation about which you just testified.
A It is.
Q And the description of that $80,000 reads that it
came from the Heritage Foundation. It describes the Heritage
Foundation, and then it states that "INSI . . ." — and I'm
quoting-- "managed a grant by Heritage to produce a study on
foundation information services in the Caribbean and Latin
America." Is it fair to say that that's not an accurate
description of what that $80,000 was used by INSI for?
A It's fair to say that that's not a completely
accurate characterization of what the $80,000 was used for.
Q You testified a bit earlier this afternoon that you
rue the day when you wrote about five or six words that were
contained in your February 1987 report. Do you also rue the
day that you wrote that description of what INSI did with
that $80,0007
MR. DUDLEY: I object. Whether he rues the day has
no bearing. What's the point of a question like that other
than sheer harassment? I'm hoping that Mr. Kaplan is going to
respond to my inquiry.
MR. KAPLAN: I'm asking for an answer.
MR. DUDLEY: I want to know what the predicate for
the question is. What is the basis of a question — what is the
relevance of a question about whether he rues day he wrote
something, to this investigation or any other investigation;
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MR. KAPLAN: I was just using the witness' phraseol-
MR. DUDLEY: That's something he said about another
thing, but that doesn't make it relevant to —
BY MR. KAPLAN:
Q Fine. I will withdraw the question, and I will ask
whether you would describe what INSI did with the Heritage
Foundation differently if you had it to do again today.
A Yes.
Q I really wasn't trying to harass you. I really
kind of liked your turn of the phrase before.
Was there--you testified before about a subsequent
contribution of S60,000 that also came through Mr. Godson to
INSI.
A I believe it came through Mr. Godson, but it was
certainly — I was made aware of it by either Mr. Godson or Mr.
North, and frankly I can't recall which.
- Q And was the $60,000 paid to INSI?
A Yes .
Q Do you recall who the contributor was in that
instance?
A It was in our check ledger as Macaleer, and I have
asked the bank for the cancelled incoming check which they
would have a copy of, and they informed us last week that
they did not keep a copy of it. Or rather, they have lost a
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copy of it. So I haven't been able to get my hands on it.
You're not the only people in town that want it.
Q Do you recall when that contribution was made?
A It seems to me that it was right around the first
of the year in 1986.
Q Do you recall what INSI did with that contribution?
A It transferred it immediately out to Lake Resources.
Q Has INSI filed a Form 990 for 1986?
A Yeah.
Q Do you recall how that $60,000 contribution that
was then sent on to Lake Resources was treated on that Form
990?
A I think. it's been amended since it. was filed, and I
think the amendment simply s'tates that it was- money for the
Nicaraguan resistance at the direction of Lt. Col. Oliver
North.
Q Has there been any attempt to amend the Form 990
that's been marked as Exhibit 21?
A No.
Q If it doesn't impinge on an attorney-client
communication, can you tell us why there's been no attempt at
amending that Form 990?
[Recess for witness and attorney to consult)
MR. KAPLAN: Can we go back on the record?
MR. MILLER: I don't know. There's really no
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answer to your question. I hadn't thought about it, frankly.
BY MK. KAPLAN:
Q When did you first meet Adolf o Calero?
A Some time in 1984.
Q In what context did you meet Mr. Calero?
A Frank set up a breakfast between himself, Adolf o
Calero, and myself.
Q What was the purpose of that breakfast?
A To talk to Mr. Calero about the potential of IBC
representing him in Washington.
Q Was Mr. Calero referred to within IBC by the name
"Spark Plug"?
A Yes.
Q Who coined that name?
A Frank did.
Q Do you recall the derivation of the code name?
A Sure .
Q Why don't you tell us about it.
A Well, again, you try and make it something that has
some relevance to his actual name, and his initials are AC,
and AC is a spark plug, so that's why it was "Spark Plug".
Q Was one of the contra leaders referred to as
"Clutch"?
A Yes.
Q Who coined that name?
Miffla
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A Well, since Mr. Matamoros was part of Mr. Calero's
organization, we just continued the automobile convention,
and he became "Clutch".
Q Mr. Matcimoros was "Clutch".
A That's correct. I think I coined that one.
Q As a result of the breakfast among you and Mr.
Gomez and Mr. Calero, did a professional relationship arise
between Mr. Calero and IBC?
A Yes.
Q what was the nature of that relationship?
A We were the media relations and political consul-
tants to the Nicaraguan Development Council, which again
served the domestic interest of the resistance.
Q Was Mr. Calero at that time head of the Nicaraguan
Development Council?
A I don't think you could use the word "head". He
was certainly the principle beneficiary, as was his organiza-
tion, of the Nicaraguan resistance.
Q From whom did IBC receive payment in connection
with those services?
A Primarily from Mr. Calero, sometimes from Mr.
Mateunoros .
Q Was there an agreed-upon payment at the inception
of the business relationship?
A Yes. Initially we were jJaad ■$3 /OOO • a month, and
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then it became clear that they couldn't follow through on the
level of increasing activity that our efforts were producing
without more administrative help. So we asked for $5,000 a
month, and under that contract we were responsible for
providing a full-time employee in their office, the admini-
strative details, the computer handling their distributions,
and so forth.
Q When did that increase occur?
A I can't recall specifically.
Q Let's just get a few dates straight. When did the
business relationship begin, to the best of your recollection?
A I want to say September of '84.
Q Do you have any recollection as to how many months
into that relationship month-ly fees were raised and you put
an employee full-time into their office?
A Some time around the first of the year, I think. I
think I've shortened this time frame. I think it was almost
a year. I think it's about nine to ten months worth of
activity. So it's probably somewhat earlier in the year than
September. And the employee — maybe in September.
Q In September of what year?
A That would be September of '84.
Q You testified a bit earlier about an exhibit which
was marked as Exhibit No. 11, which is a letter of authoriza-
tion from Mr. Calero to Mr. Channell authorizing Channell to
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engage in fundraising on behalf of the FDN. Did you or
anyone at IBC or IBC itself receive a fee for obtaining that
letter?
I don't recall receiving a fee.
From either Mr. Channell or anyone else?
I don't recall receiving a fee to obtain that
A
Q
A
letter.
Q
9 Council?
10
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A Generally in traveller's checks, although a couple
of times we received wire transfers.
Q Were they traveller's checks that were given to you
by Calero?
A Yes . Sometimes we- got them from Matamoros , but I
don't think very many times.
Q Were they blank traveller's checks?
A They were totally blank — just a bank name, and
everything else on it was blank.
Q Do you know why Calero didn't write the checks out
to International Business Communications and sign them on the
bottom?
A No.
Q Did you ever ask him why?
A I never asked, but my sense was that most of their
activities were cash activities, and a blank traveller's
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check is as good as cash. And as a consequence, it was safer
because it was not something that could be lost.
Q Did Colonel North ever give you any blank trav-
eller's checks?
A I don't ever recall receiving traveller's checks
from Colonel North.
Q You mentioned a bit earlier today that Jonathan
Miller at one time waved some traveller's check, I think, in
front of Frank Gomez as a show of good faith or something to
that effect.
A It was in front of the Nicaraguan Meskito Indian
Leader. Stedman Fogath or Diego Wycliff — I can't remember
who it was .
Q Did you have an understanding as to where Jonathan
Miller got those traveller's checks?
A He was in Colonel North's office suite at the time
he did it. So I assumed they came from there.
Q But you yourself don't recall ever having received
from North any traveller's checks that were provided to him
by Calero or anybody else?
A I don't ever remember getting traveller's checks
directly from Colonel North. There was one instance in a
hotel room here in Washington where there was an exchange of
traveller's checks between Dr. Calero and Colonel North, and
we ultimately got some of those traveller's checks. That's
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the only time which that happened, that I can recall.
Q Can you describe that incident in a bit more detail
so that we can have for the record a clear reflection of what
took place in that hotel room? I guess you could start out
by telling us approximately when that exchange took place.
A Well, it was in the evening. The exact date I'm
not sure of. It was at the Henley Park Hotel. I either went
there with Colonel North or I met Colonel North there. We
went to Mr. Calero's room. Mr. Calero had a large envelope
of traveller's checks. Knowing what I now know about their
volume, I'd say it had to be at least $20,000 in traveller's
checks. They had a discussion about names that seemed
familiar to the two of them, and I believe Mr. Calero gave
the traveller's checks to Colonel North.
And my reason for being there was that some of those
checks were supposed to come to me. And the best recollection
I have is that it was about the time I put Maritsa Herrera,
the little girl, in Children's Hospital and took the money
from my account to pay for that. It was $10,000 to Children's
Hospital, and that may have been reimbursement for that.
Q When was that?
A It was right about the time of the Nicaraguan
refugee fund dinner. In fact, she was there for the Nicar-
aguan refugee fund dinner, and her wound had not been
attended to. And she was about to lose her arm, and I
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guaranteed her hospital stay to Children's Hospital.
Q So that would have been in April of 1985.
A That would be about — well, whenever the dinner was,
so April, I guess.
MR. KAPLAN: Off the record for a quick minute.
MR. KAPLAN: I'm going to ask the reporter to mark
as Exhibit 22 a composite exhibit which is comprised of
several traveller's checks dated variously from I believe
March 20 through April 18. I have only made two copies of
these volumes.
[The document referred to was
marked for identification as
Miller Deposition Exhibit No.
.22.]
MR. LEON: Can the record reflect a rough estimate
of how many checks there are? How many pages would you
approximate?
MR. KAPLAN: If I'm not mistaken, there are
approximately $5,000 worth of traveller's checks that are
represented by this exhibit.
MR. LEON: Are they all $100 checks?
MR. KAPLAN: Yes, I believe so.
Mr. Miller, you've seen these checks once before and
actually, as I recall, had an opportunity to lunch with them
and your counsel. I'm going to ask whether any of these
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checks refresh your recollection as to whether or not you
ever — as to whether you ever received any traveller's checks
from North that had been provided to him by Calero or anyone
else.
MR. DUDLEY: Well, he's testified as to the
incident at the hotel .
MR. KAPLAN: Right. That's correct. Other than
that.
MR. MILLER: It doesn't refresh my recollection.
Other than that, I can't remember an instance.
MR. KAPLAN: To the best of your recollection — and
you've been through these checks once before — would these
checks represent other than possibly the hotel incident,
checks that were given to you directly by Calero as payment
for services performed on behalf of the Nicaraguan Development
Council?
MR. DUDLEY: Before he answers that question, I
assume — but I would like your representation — that this is
the same bundle of checks that he did look at.
MR. KAPLAN: This is the same bundle of checks that
was reviewed by Mr. Miller a couple of months ago.
MR. MILLER: I would assume, since I got paid in
traveller's checks and usually from a Latin American bank,
that that's true. I never kept track of the traveller's
checks after I cashed them
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BY MR. KAPLAN:
Q Did Colonel North ever ask you to cash traveller's
checks for him?
A I don't ever recall being asked to cash traveller's
checks .
Q Did Mr. Calero or anyone else ever ask you to cash
traveller's checks and return the money to some party other
than yourself?
A I don't recall doing that.
Q So it's your testimony that any traveller's checks
here or that you received from Mr. Calero or possibly from
North during that hotel incident which you described before —
checks that would have been in payment for seirvices performed
by IBC on behalf of the Nicaraguan Development Council.
A That's my recollection.
MR. DUDLEY: Or reimbursement of hospital expenses.
MR. KAPLAN: Right. Or reimbursement of hospital
expenses .
BT MR. KAPLAN:
Q Do you ever — do you recall having given Mr. Robelo
cash in front of a hotel in Washington?
A Yes. I gave — I'm not sure whether it was cash or
traveller's checks. And with the IRS right around the
corner, I wish I knew the answer to that one right now. We
paid his hotel bill one time, and I gave it to him in cash
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because they weren't accepting his MasterCard, as I recall.
And it seems to me it was somewhere in the neighborhood of
about $2,000 or $2,500 or something like that.
Q Do you recall when that transaction took place?
No.
1985?
I really don't recall when.
Did North ask you to give Robelo the cash?
Yes.
What was the source of the funds to which you gave
A
Q
A
Q
A
Q
Robelo?
A
Would have been NEPL funds that Colonel North
thought he had access to.
Q So it would have been some time after July 1985.
A Probably .
Q And some time before December 1986.
A Probably .
MR. KAPLAN: Let's knock off for today.
[Whereupon at 5:34 p.m., the deposition was concluded
UNCUSSIFIED
297
U*l
CERTIFICATE OF NOTARY REPORTER
I, Terry Barham, the officer before whom the
foregoing deposition was taken, do hereby certify that the
witness whose testimony appears in the foregoing transcript
was duly sworn by me; that the testimony of said witness was
taken by me and thereaftrer reduced to typewriting by me or
under my supervision; that said deposition transcript is a
true record of the testimony given by said witness; that I am
neither counsel for, related to, nor employed by any of the
parties to the action in which this deposition was taken;
and, further, that I am not a relative or employee of any
attorney or counsel employed by the parties hereto, nor
financially or otherwise interested in the outcome of the
action.
Terry
and
y Bbrhan^xfiota
for' th/oistri
(otary Public in
District of Columbia
)07 C ... N.I.
My connnission expires Hay 15, 1989.
UNCUSSIFIED
298
i'artUIly Dcd«MMi/R«feMed on - i^ Ji] ^r ^ r
mdm provisions : i £.0. 12356
-*)r O. Mb, Nalioncl iecuHty Coundl
299
DNCUlSSIfe
294
SELECT COMMITTEE TO INVESTIGATE COVERT
ARMS TRANSACTIONS WITH IRAN
U.S. HOUSE OF REPRESENTATIVES
AND
SELECT COMMITTEE ON SECRET MILITARY ASSISTANCE
TO IRAN AND THE NICARAGUAN OPPOSITION
UNITED STATES SENATE
Friday, August 21, 1987.
Washington, D.C.
Deposition of RICHARD RODERICK MILLER taken on
behalf of the Select Committees above cited, pursuant to
notice, commencing at 8:40 a.m. in Room 901 of the Hart
Senate Office Building, before Terry Barham, a notary public
in and for the District of Columbia, when were present:
For the Senate Select Committee:
JAMES B. KAPLAN, Esq.
Associate Counsel
For the House Select Committee:
JOHN FRYMAN, Esq.
SPENCER OLIVER, Esq.
RICHARD J. LEON, Esq.
■MLUM nromwta co.. nc
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(20''1 146-MM
UNCLASSIHED
300
295
UNcussro
For the deponent:
EARL C. DUDLEY, JR., Esq.
"
Nussbaum, Owen & Webster
One Thomas Circle
Washington, D. C. 20005
CONTENTS
Examination by counsel for
Paqe
Senate Select Committee
296
EXHIBITS
Exhibits
Marked
23
317
24
325
UNCLASSIFIED
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ONCUSSIHED
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whereupon,
RICHARD RODERICK MILLER
the witness on the stand at time of adjournment, resumed the
witness stand and, having previously been duly sworn, was
further examined and further testified as follows:
EXAMINATION BY COUNSEL FOR
THE SENATE SELECT COMMITTEE (Continued)
BY MR. KAPLAN:
Q Mr. Miller, this is a continuation of the previous
sessions of your deposition taken pursuant to immunity orders
of the Senate and the House, which are Exhibits 1 and 4,
respectively, in this deposition. I would simply remind you
that you are still under oath.
I just want to refer you back, for a moment, to
what was marked late yesterday as Miller Deposition Exhibit
Number 22. That is a composite exhibit of a stack of
traveler's checks that were signed and cashed by you.
I asked you yesterday, whether or not you were ever
asked by anyone, or whether you cashed any of these checks
for anyone other than yourself, and I believe you responded
that you could not recall ever having done so.
I simply want to ask you whether it refreshes your
recollection on that response, or whether it changes that
response at all, if I told you that we've determined that the
checks that were cashed on March 28th are consecutive in
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number with checks that were cashed by Robert Owen and
Jonathan Miller at the request of Colonel North?
A No, that doesn't change my statement.
Q So I take it that your testimony is that to the
best of your recollection, all the checks here which you had
an opportunity to review with counsel, back in June, and then
again, briefly, yesterday, are checks that were attributable
either to compensation paid to you by Mr. Calero on behalf of
the Nicaraguan Development Council, or as part of a hotel
incident to which you testified yesterday?
A Or potentially, the reimbursement of the expenses
for the little girl that I put in the hospital.
Q Okay. Thank you. Staying with Mr. Calero for a
moment, what kind of knowledge did you have back in 1985 and
1986 of bank accounts that were controlled by Mr. Calero?
A Hell, the ^^^^^^^^^^Haccounts were clearly Mr.
Calero 's accounts, and I think I knew that from the beginning
of my transfers to those accounts.
. Q Who would have told you that thei
accounts were Mr. Calero's controlled accounts?
A Colonel North.
Q Were there any other accounts that were under Mr.
Calero's control about which you had some knowledge during
1985 and 1986?
A Well, checks were made out to the Nicaraguan
t which you had some knov
ONOUSSIFiED
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ONCLASSinED
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Development Council in a couple of fund-raising situations.
Where they were deposited, I'm not sure, to be honest with
you. Those are the only ones I can remember.
[Witness and attorney consult.]
THE WITNESS: The Lake Resources account was to our
understanding an account that was for the benefit of Mr.
Calero. It was never clear, initially, who it was, but that
was our understanding.
BY MR. KAPLANt
Q When you say it was for the benefit of Mr. Calero,
was it your understanding that Mr. Calero controlled that
account?
A I don't think I was ever told that he controlled
it. It was just clear that that — whoever that Lake Resources
organization was, they were actively involved in the support.
And the items that were being asked that we fund-raise for,
and those vo transferred money for, were for things that
would have been virtually impossible for him to miss. The
heavy lifting system, aircraft. In the case of the surface-
to-air missiles, so — that ultimately became radios, but they
ended up on the ground, so —
Q Now over time, you developed a fairly close
relationship with Mr. Calero, it's fair to say, is that
correct?
A Yes.
im
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LASSIFIED
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Q Did you ever discuss the Lake Resources account
with Mr. Calero?
A Yes, in December of 1986.
Q Any time before that, do you recall a discussion
with Mr. Calero about Lake Resources?
A No.
Q None at all?
A No.
Q Did you ever discuss with Mr. Calero disbursements
from the IC, Inc. account to Lake Resources, that were made
at the direction of Colonel North?
A Only once. Colonel North told me that Mr. Calero
was in desperate need of money for a food bill, and asked me
to go to his hotel, at the Connecticut Club, and to tell him
that I had a donor from outside the United States, and that
individual wanted to give him — I believe it was $150,000 — and
that I should ask him for an account.
Of course the account would be exactly the same
account that had been given before, but apparently Mr. Calero
was unaware that I was the individual transferring the money
into his account. So I did. I went to the hotel. He
immediately asked me for $250,000, but I told him there was
150 available, and he wrote the account number down for me,
and it was identical to what I had used for previous transac-
tions. And I transferred money into that account.
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Mr. LEON: Let me just ask one follow-up. when you
say Mr. Miller, that the Lake Resources account to your
understanding was for Mr. Calero, you don't mean for him
personally, but rather, for the contras?
THE WITNESS: That's correct, because it was used
to buy things like heavy-lifting and Maule aircraft, and
radios, and surface-to-air missiles, and so forth.
BY MR. KAPLAN:
Q When you say that the account number that Calero
wrote down for you was identical to the account that you had
previously used, could you just clarify for the record which
account niomber you're talking about.
an ^^^^^^^^^^^^^^Haccoun
ii^^^^^^^^^^^^B
Q Do you recall when Colonel North first told you
about thisB^^^H^^^^Haccount, and that was under Mr.
Calero 's control?
A Not offhand, but he would have done so immediately,
prior to the first transaction ^C'^^^^^^^^^H, so whatever
Q Do you recall Having instr-icted Mr. Channell to
check to^^^^^^^^^^^^that was being given by
Channell to Mr. Calero, for his behalf, back in June of 1985? '
A Yes. At one fund-raiser in the Hay-Adams, Mr. !
Channell asked who the check should be made out to, and Mr. j
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SSIFIED
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Calero said — I went and asked Mr. Calero and he said^^^m
And then, I think it was the next morning, when I
told Colonel North that it had been made out ^°^^^^^
^^^^^|. He said that that was wrong, and I believe it was
changed to the Nicaraguan Development Council.
Q Okay. I'm going to march, briefly, with the State
Department contracts that were held by IBC. Hy understanding
is that Mr. Fryman is going to cover them in more depth at
the next session.
I understand that IBC had, over time, from 1984
until September of 1986, I believe you testified yesterday a
number of consecutive State Department contracts, is that
correct?
A Correct. Yes.
Q To your knowledge, were those contracts obtained
from the State Depeurtment?
A Well, initially, Mr. Gomez's expertise was sought
out' by the office that had newly been created by Ambassador
Retch. Frank is 20 years in the Foreign Service. Most of
it's been in Central and South America. He's fluent in
Spanish, Portuguese and French. Speaks some Italian. And is
extremely well known by people in Central America, senior
officials, journalists. In fact was the originator of one of '
'i*!iSS!FIEIl
So, that was exactly the type of individual that |
the journals and associations down there < <i|'''>S
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the State Department Office of Public Liaison needed, or,
public diplomacy needed to begin their mission.
Q When was the first such contract let to Mr. Gomez?
A I think it was signed on February 22nd, 1984.
Q So that was shortly after he retired from the State
Department?
A That's correct.
Q Were those contracts, or was that contract, that
same contract, renewed at some point in time?
A It was. It was actually a purchase order contract,
and it was reissued, I believe two more times.
Q To Mr. Gomez?
A To Mr. Gomez. That's right.
Q Do you recall what the average length of these
contracts was?
A It seems to me they were about 3 months.
Q Was there a time when the contracts were let to IBC
instead of to Mr. Gomez?
- A Well, when Mr. Gomez and I began to form a partner-
ship in '85, he requested that the contracts be made to
himself at International Business Communications, and as we
began to form the partnership he simply brought that in as
part of — it was already a consulting contact for him and he
brought it in as part of the partnership business.
Q Was IBC then listed as the contractor on the
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contract itself?
A In those three contracts, no. In the fourth
contract I believe yes, but again, using his name and
International Business Communications.
Q How many contracts were there, all-told?
A I believe total, there were six. Seven. I'm
sorry. Seven, including the INSI contract.
Q How many of these contracts were identical in terms
of the duties performed by Mr. Gomez and IBC?
A That's not the right question. The elements that
were in the first three contracts were also in the fourth
contract and in the fifth contract. The fifth contract, the
larger of all of them, a 200 and some-thousand dollar
contract, had in it an additional section for a distribution
system.
So the elements did not change significantly from
the first contract to the last contract, except for the
increase to incorporate a distribution system.
. Q Okay. What was the sum total of these seven
contracts?
A About 440-some thousand dollars.
Q All right. You mentioned that one of the contracts
ufr'
was over $200,000? IK
A Yeah. We bid it at 242 — or 342, and they told us
mentioned that one of
NCLASSIRED
it was going to cost — I'm sorry. We bid it at 242. They
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told us it was going to cost 282, and we came in at 276, I
believe.
Q Were the other contracts reasonably equal in amount?
A I think they were almost exactly equal. The fourth
contract was nothing other than a longer time period. The
previous three contracts had all been purchase orders, so
they were for short periods of time.
Q So they were in the range of 40 to $50,000 each?
A I think the first three contracts were slightly
under $10,000 each, and I think the third contract— the
fourth contract was about $90,000.
Q what duties did Mr. Gomez, and others at IBC,
including ourself, perform under these contracts?
A Let me see if I can do it again, off the top of my
head. We provided escort services for exiles, refugees,
atrocity victims. We provided translation services for the
same people. In some cases we provided security for them.
We provided simultaneous interpretation. We
provided housing, transportation. We provided media contact
for these same people. We provided civic-leader contact for
these people. We sought to put the
organizations in the United States.]
We did debrief ings for them. We set up interviews
and press conferences. We arranged television appearances
For the office in general we provided text for op-eds ,
ims»o
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INCUSSIRED
305
editorials, letters to the editor, articles, translations of
publications outside the United States that were then
distributed by the office.
We helped arrange media schedules, made strategic
planning suggestions for development of public expressions of
policy. We helped draft reports on public-affairs strategies.
We helped edit texts for speeches. In the distribution area
we created a computerized database for the use of the office
in the distribution of its publications.
They could be segmented into multiple selection
processes so that they could be distributed by subject, by
geographic location, by a whole host of demographics. We set
up an internal control system to improve the procedures
associated with the production and ultimate distribution of
publications .
We provided staff on site at State Department to
handle that task. We did the actual physical distribution of
hundreds of thousands of pages and single documents. I
remember one distribution being 70,000 copies. We provided
the delivery of those to the Federal agencies that were
involved in the matter here in Washington. We provided the
transportation and the storage for those documents. And we
also provided a training course for the information office of
the Salvadoran government.
iCUSSIHED
And we provided talking points for, or suggested
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talking points for senior administration officials. That's
all I can remember, off the top of my head.
Q Is it fair to say that in your work under these
contracts you were brought in close and regular contact with
Mr. Calero, Alfonso Robelo and Arturo Cruz?
A No.
Q Did you coordinate any of their travel or visits to
the United States?
A Yes.
Q Was that a service that you performed under these
contracts? Or was that a service that you performed in
connection with your duties that you described yesterday on
behalf of the Nicaraguan Development Council?
A We considered it duties on behalf of the Nicaraguan
Development Council. Initially, also, our work with the Gulf
and Caribbean Foundation.
Q So is it fair to say, then, that at least your work
on behalf of the Nicaraguan Development Council brought you
into fairly close and regular contact with Mr. Calero, Mr.
Robelo and Mr. Cruz?
A Yes.
Q Did North ever contact the State Department on
I EC's behalf, to your knowledge? ;^ Sji
ui
cifj
CLASSIFIED
A I don't recall the specific instance but I've read
the press reports on it, and I have a minor memory of him
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doing so.
Q And do you recall when he made that contact?
A I don't recall when but I recall why.
Q Could you tell us why.
A Yeah. We had billed the State Department for three
months' worth of work, and I think it was already 30 days
past the time that that should have been paid under the Prompt
Payment Act. And we were just not that big a company, it was
a very serious time for us, and we needed the money, and he
made an appeal to somebody at the State Department. I've
forgotten exactly who it was.
Q Why did you approach North to make the appeal on
your behalf?
A I'm not sure I approached him on it. I think I
just may have bellyached in his presence and he acted.
Q He acted?
A Yes.
Q Did he tell you that he had contacted someone at
State on your behalf?
A I don't remember whether , he told he was going to,
or whether he told me he did.
But one of t
Yeah.
ilASSIFIED
Q Did his contacts result in prompt payment?
A I guess the Government would have considered it
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WSIFIED
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prompt payment. I'm not sure it came much quicker than it
would have been otherwise.
Q Do you know who he contacted at the State Depart-
ment?
A I want to say Frank Gardner, but I'm not sure. It
was the administrative — it was somebody involved in the
adminstration of the Office of Public Diplomacy.
Q Was that one of Mr. Gardner's duties?
A Yes.
Q Who were your principal contacts at the State
Department under these contracts?
A Well, it changed as the staff changed. Initially,
it was Otto Reich and Jonathan Miller, John Blacken, John
Scafe. Those were the people we answered to, initially. And
also, we worked with Mary Catherine English, Jake Jacobowitz,
Colonel Larry Tracy, Colonel Mark Richards, Dan Fiske, Bob
Kegan. Those are all the names I can remember, off the top
of my head.
- Q I'm going to move off the State Department con-
tracts. As I said, those will be covered in more depth, I
understand, at your next session.
When did you first meet Jonathan Miller?
A I met Jonathan in the campaign in 1980.
Q What kind of contact did you have with him after
the campaign?
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A We both ended up at AID, myself In the Public
Affairs Office, and Jonathan in the Legislative Affairs
Office.
Q Did you and he develop a friendship?
A Yes.
Q Did you ever discuss with him — and I think I asked
you this yesterday, but if I did, you can just give me the
same answer. Did you ever discuss with him your contra-
funding efforts with NBPL and Colonel North?
A I don't recall ever discussing it.
Q All right. Do you recall having had some meetings
with Jonathan Miller and Colonel North?
A I'm sure I have but I don't — I recall one meeting
in the situation room, that I think Jonathan was at.
Q What types of substance — if it can be broken down
that way — was likely discussed in meetings that you would
have with both Mr. Miller and Colonel North?
MR. DUDLEY: I object to the hypothetical way in
which that question was framed. Tou know, what questions
were likely discussed, if there were meetings.
I think you should establish whether there were
meetings .
MR. KAPLAN: I'm sorry. I_th2Waht I had established
that before.
THE WITNESS: Would it be helpful for me to
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remember each meeting? i would go as far as my memory goes
on each one of them.
BY MR. KAPLAN:
Q Okay. Why don't I help you out a little. Records
that the Committees have obtained in the course of their
investigation show that you and Colonel North, and Mr. Miller
had meetings on the following dates, and this may help you
place yourself, and maybe recall some of the substance of
those meetings .
September 10, 1984 with Mr. Gomez also in atten-
dance .
January 16, 1985, with Mr. Gomez also in attendance.
MR. DUDLEY: What was that second one? I'm sorry.
MR. KAPLAN: January 16, 1985.
It is unclear, but perhaps meetings with a group
called Citizens for America on January 25 and January 28 of
1985.
February 27, 1985 with Mr. Gomez and Mr. Owen also
in attendance.
June 5, 1985 with Mr. Gomez and a person named
Otto, who I presume is Otto Reich.
THE WITNESS: June 10?
MR. KAPLAN: June 5, 1985. I believe that's the
sum total .
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BY MR. KAPLAN!
Q So all those meetings vrould have taken place between
September of 1984 and June of 1984, according to our records,
I certainly welcome any further recollection you have beyond
what we have on paper. I also will note for the record, that
the September '84 meeting is not clustered with the rest. It
seems to sort of hang out by itself.
Does that refresh your recollection at all as to
the substance of the meetings that you did have with Colonel
North, Mr. Miller, and, usually, others?
A I can probably identify three of these, and I'll
work backwards, chronologically. The June 5 meeting with
Otto Reich, I believe was at lunch. The third meeting I can
recall is a Citizens for America meeting, which I believe only
took place on one of those dates. I think you probably have
a vintage North calendar entry that got changed several
times, and that in reality it took place at some, one of those
but not both of those.
~ I was invited to a meeting in the situation room
that was attended by — was hosted by Colonel North and was
attended by Otto Reich and Jonathan Hiller, Frank Gomez and
myself. Lew Lehrman, Jack Abramoff, and two other officials
of the Citizens for America whose_neUiiea. I cannot remember
right now. ll
Was thaY a meeting in which I believe that your
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counsel have produced to us a document listing the attendees
at that meeting with phone numbers on the righthand column?
A Yea.
Q Okay.
A And Lehrman had asked for the meeting. His
intention was trying to create political support for the
President's policy. Colonel North introduced us as represen-
tatives of Mr. Calero. We sat through a presentation by Mr.
Lehrman of a fairly weighty and seemed to be a well-thought-
out program of grassroots education, and Colonel North asked
what the Administration could do to help, and Mr. Lehrman
said that he needed to have $250,000.
So everybody's immediate reaction, unspoken, was
the same, and that was that that was his business to raise
the money and not ours, and that we thought we were being
offered help and not asked for it, in terms of funding.
So I think the idea basically exhausted itself and
wenl no further.
- Q Okay .
A I remember — and I can't tie them to these other two
dates, January, or SeptembenlO 1984, or February 27th — but I
remember being called over to North's office — Frank and I
both, by Jonathan Miller, and that Jonathan was housed there
at the time.
And the UNO leaders ITaS^coflS^to Washington, and
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^
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Colonel North asked that we get for them media, and we used
his telephone, and then ultimately, went back to the office
and got things like Good Morning America, the Today show,
Nightline, and Washington Post.
Q Do you recall when this incident took place?
MR. DUDLEY: Will you excuse me just a minute.
[Witness and attorney consult.]
MR. DUDLEY: I'm sorry to interrupt your flow, but
I wanted to get something before it got too far past.
MR. KAPLAN: It's okay. I appreciate that.
BY MR. KAPLAN:
Q Do you recall when the call from Jonathan Miller
came and this incident took place?
A It would have been — no, I don't recall the exact
date. It may be the February meeting — I'm not sure--but it
would have been just about the time of the President's first
request for aid.
Q How did North, to your knowledge, first become
aware of your association with Mr. Calero?
A I don't know. I've never remembered our first
meeting, so I can't even tell you why we--
Q Okay. When did you first meet Rob Owen?
A Again, I'm not sure when my first meeting with Rob
was. The earliest recollection I have of Rob is he accom-
panied a group of three refugees to our offices, along with
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John Hall, and we were in our offices at 1607 fiew Hampshire.
So it would have had to have been some time between February
of 1984 and January of 1985.
Q Who sent Mr. Owen to your offices with the refugees?
A I don't know. We didn't know he was coming with the
refugees. I think we expected the refugees, and Mr. Owen and
Mr. Hall showed up with them, along with two other in-
dividuals .
Q Can you briefly describe the substance of your
relationship with Mr. Owen over time, starting with that
first meeting with the refugees, and continuing on through the
end of this year?
A Rob was a personal friend of mine. We have had a
minimal amount of professional contact. I reviewed a public-
affairs strategy he produced one time. He has provided me
with background information, that he has secured a lot of
this down in Nicaragua and^^^^^^^B That's about the extent
of Our professional relationship.
- Q I want to go back to a question I forgot a moment
ago. When Mr. Calero told you in December 1986 who con-
trolled Lake Resources, or what Lake Resources was —
A You mean Lake Resources or
Q Maybe I misunderstood, then, and it's worth
clarifying for the record. I thought I had asked you when did
you discover that what the Lake Resources account was.
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A No, that wasn't your previous question, but I'd be
happy to answer it.
Q Okay.
A When Albert Hakim testified before the Congress, my
first inkling that it was more than Just an account to assist
the contras came when I read the front-page article that
quoted H. Ross Perot as having been asked to send $2 million
there.
Q That would have been in December of 1986?
A I believe it was December 6. It was a revelation.
Q Was your earlier testimony about a discussion with
Mr. Calero in December 1986 relating to his control of^^^^
A Correct.
Q But I take it, as you testified, that you had some
inkling, some time prior to December 1986, that Mr. Calero
knew about that account, if not controlled it?
A No, that's not what —
- Q Is that not correct?
A No, that's not what I said.
MR. DUDLEY: I think you'd better clarify that.
" "IMSliHl"""" ■'"
THE WITNESS: I was always under the impression
that the Lake Resources account was some form of organization
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that benefited the resistance, because we raised items which
then appeared in newspaper articles, and so forth, down
there. They also would have been impossible for Mr. Calero
to miss. Big airplanes, heavy-lifting systems, Maule
aircraft, shoulder-launched missiles.
So I always assximed that he was aware of the Lake
Resources account. It wasn't until December of this past
year, that I realized that he knew very little about the Lake
Resources account, and that was only after discussing it with
him directly.
BY MR. KAPLAM:
Q Let's go back to Mr. Owen. Did you ever discuss
with Mr. Owen your role in contra-assistance funding NEPL?
A I don't recall discussing it with Rob, no.
Q Did Mr. Owen ever discuss with you his role in a
contra-resupply network, or a contra-resupply operation?
A I don't believe so.
Q Did Colonel North ever discuss with you Mr. Owen's
rol« in the contra-resupply operation?
A Not in a resupply operation per se, but as a
courier and a carrier of messages from him to political
leaders.
Q What did you| Iff^Sf'^^f^OMt^^Ij^ ^Qjj^ij^'^^relationship with
Colonel North?
A I thought that Mr. Owen was employed almost solely
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by Colonel North.
Q Were you aware that Owen had been at least in part
placed by North at the Nicaraguan humanitarian aid office?
A Not until I read it in the newspaper.
MR. KAPLAN: I am going to ask the reporter to mark
as Deposition Exhibit Number 23 a copy of a document provided
by your counsel, which are handwritten notes.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 2 3. ]
MR. KAPLAN: The top of the page says "IBC expendi-
tures for Green. "
BY MR. KAPLAN:
Q I first want to ask you if you recognize those
notes .
A Yes. They're mine.
Q Does "expenditures for Green" refer to expenditures
by IBC for Colonel North, or at his request?
" A At his request, or for him, right.
Q All right. The date, 1985, refers to the year in
which these expenditures _w^rjjn|d^?
A Correct.
Q The very first entry I believe says, "S-lS-'that
is, June 19--and it says "Owen trip expenses." Then the
corresponding number is $2200. Were you aware at the time
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that Colonel North was asking you to make certain distrurse-
ments, that some of these disbursements were ta pay for Mr.
Owen's travel?
A Yes. In fact the first two items are actually
interconnected. The $2200 I believe was cash, and the 3500 I
6 l| believe was traveler's checks for him to take with him.
i|
7 I Q Who provided you with the traveler's checks for Mr.
i!
8 1 Owen to take with him?
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A This came out of our bank account. In other words,
we wrote a check to our bank and got traveler checks, and
gave them to .Mr. Owen.
Q I see. Does "NDC" stand for Nicaraguan Development
Council?
A Yes.
Q If they were traveler's checks taken out of your
bank account, why would the notation says "NDC traveler's
checks?"
A At that point I can only assume that it was because
I thought Rob was working primarily with Calero's orga.-.iza-
tion, and I would have put NDC down.
Q Is it possible that at that time you gave to Mr.
Owen the blank traveler's checks' that had been given to you
by Mr. Calero irt^iDfW^ i^A P^^t iMViF^^ that you had
24 performed?
A I don't think so because I think there's a check
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that corresponds to this in our check register, and I believe
that was--I mean, I think "NDC traveler's checks" is just a
mental note to myself as is "Wire to Lake" or one of the
others .
Q Move down two entries from there to a September 12th
entry which I believe says "Beacon Creative Writing, $10,000."
Can you explain to us, briefly, what that disbursement
represented.
A Beacon was the name that I chose for Arturo Cruz,
Sr. and —
Q He wasn't a "car part?"
A No. He was a great deal of light. He was an
"illuminating force" so we called him Beacon.
Q But you could have called him Headlight.
A That's true. He was to write an article and that
$10,000 was payment for the writing of the article.
Q I take it that the other entries that are shown,
which I believe we covered yesterday — an entry for Commercial
Tulin, anjthen several wires to Lake, are simply disbursements
from IBC that were made at Colonel North's direction?
A Correct.
Q Did all of these disbursements come from money that
had been passed to IBCaicsri WffL A M4%l>n^Pntended for
contra assistance?
A Either passed to us, or — yes, it all came from NEPL
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money.
Q When did you first meet Father Tom Dowling?
A I think it was fairly late. I think it was like
1986.
Q When, in 19867 Do you recall?
A I don't. I recall, I think he was in Adolf o
Calero's presence when I met him.
Q Were you aware that Father Dowling was a principal
of the Latin American Strategic Studies Institute?
A Yes.
Q Were you aware of that fact at the time that
Colonel North directed disbursements, and of IC, Inc., to the
Latin American Strateg^ic. Studies^ Institute?
A Yes.
Q Now we covered it yesterday. One of the disburse-
ments of $25,000, I believe, that went to Latin American
Strategic Studies Institute, came directly from IBC, Inc.?
A Right.
- Q I believe you testified that that $25,000 was
directed by Colonel North also?
A It was requested by Tom Dowling, and by Adolf o
Calero, and approved by Colonel North.
Q Did you ever discuss with Father Dowling your
involvement or participation in what I've been referring to
as a shorthand or a contra-funding network?
ling, ana oy Adoiro
UNCLASSIFIED
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A Not until very recently.
Q When did that discussion take place?
A The last time I saw him was about three or four
weeks ago, I think.
Q Was that discussion in the presence of counsel?
A No.
Q Can you tell us what the substance of that discus-
sion was .
A It was a friendly conversation over lunch. I don't
recall us comparing notes about much in the way of transac-
tions. We were discussing mostly the financial difficulty of
his organization at present.
Q What was the piece of conversation that you had in
which you told him about your involvement in the contra-
funding network?
A Well, I've told everybody that will listen, that
this allegation by Jane McLaughlin, that Spitz Channell gave
IBC $5 million to go to the freedom fighters, and that we
kept 2 million of it was erroneous, and it only takes then a
description of Spitz's Central American Freedom Program to
prove my point, and that's what I di'J. I described the
Central American Freedom Program.
Q Was there any other d^^usf ion ai>out your involve-
ment in the funding network?
A No.
it diWS^ion about your involv
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Q Do you recall a meeting with Father Dowling and
Colonel North, and yourself, on November 17, 1986?
A November 17, 1986? Not specifically.
Q Do you recall such a meeting generally?
A Not really. If you can give me other details,
maybe I can refresh my recollection.
Q Does it refresh your recollection at all, if i
remind you that November 17 was a Monday, and it was just a
few days prior to the meetings on November 20 and 21 about
which you've testified before here, previously, on June 23rd?
A No.
Q Does it refresh your recollection if I tell you
that the meeting took place at Colonel North's office?
A That's where I was trying to envision it. That
still doesn't click.
Q Did you travel to Panama in November 1986?
A Yes.
Q What was the purpose of that travel?
A It had to do with a client we have in Panama. It's
unrelated to this matter.
Q Did you return from Panama with some cash?
A I did.
Q Do you recall how much?
)m Panama witn some cash?
UNCLASSIFIED
A I believe it was slightly over $35,000.
Q what was the source of that cash?
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A It was $35,000 in retainer and associated expenses.
Q When you say "retainer and associated expenses,"
that's payment from a client that you had in Paneuna?
A That's correct. We reported it on the Treasury
form and our foreign-agent registration is on file with the
Justice Department.
Q Would you tell us the name of the client.
MR. DUDLEY: May we go off the record.
MR. KAPLAN: Sure.
[Brief discussion off the record.]
MR. KAPLAN: On the record.
In an of f-the-record conversation that ensued, I
was informed by counsel for the witness, Mr. Miller, that the
response to my question would divulge, on a record which
might at some point be made public, the identity of a client,
that for business purposes, and for no purpose related to
these Committee investigations, Mr. Miller would like to keep
from the public, as a matter CLf busJ.aes&-aU(ii^rofessional
propriety .
I will not pursue the question or press the
question, and I withdraw it from the record. I will state,
for the record, that counsel for the Committees have been
informed previously of the identity of that client, and that
identity is one which we intend to guard confidentially.
THE WITNESS: Thank you.
ICffiMff
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MR. DUDLEY: I appreciate that.
BY MR. KAPLAN:
Q Why were you paid in cash?
A I don't know.
Q Did you ask for a cash payment?
A No. We actually asked for a wire transfer which is
preferable, but we received cash.
Q Had you received any prior payments from that
client, or was this the first payment that you received?
A No, we had received prior payments.
Q You had. Were those payments in about the same
amount?
A Yes.
Q What was the billing basis that you had with that
client?
A It's a retainer relationship. Monthly retainer
plus expenses.
- Q Did you receive subsequent payments from that
client?
A Yes.
Q You have. Are those subsequent payments in
approximately the same ait^pyjjt^ ^f_ currency _that_ ^ou brought
back from Panama?
A At least one of them, and then our amount of
amDUDt. Sf currency that yo
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retainer was reduced.
Q . When did you first meet Richard Pena?
A I met Richard when I was at the--well, I'm not
sure, but some time before 1985.
MR. KAPLAN: I'm going to ask the reporter to mark
as Deposition Exhibit Number 24 a copy of what purports to be
a letter from Mr. Pena to World Affairs Counselors, Inc.,
dated August 15, 1985.
[The document referred to was marked for
identification as Miller Deposition
Exhibit No. 24. ]
BY MR. KAPLAN:
Q I ask you if you recognize that letter?
A Yes.
Q Is that a letter that you received as a principal
in World Affairs Counselors, Inc.?
A It is a letter I received addressed to World
Affairs Counselors, Inc., but it was delivered to me,
personally.
Q Why was the letter, to your knowledge, addressed to
World Affairs Counselors, Inc.?
A Because I didn't want _it_ addie5sed_to_ljiternational
Business Communications.
Q Can you tell us why you didn't want it addressed to
International Business Communications?
u
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A Well, it really is an offer of assistance from Mr.
Pena in securing a favorable price tag on military equipment
after the Congressional vote approving the sale of military
equipment, or the purchase of military equipment for the
benefit of the Nicaraguan resistance. And there was no
reason why that type of business should/ be handled in any way
through IBC. That's not IBC's business, and I was passing it
along as a courtesy, and I chose World Affairs Counselors
because it would have been anonymous to anybody here in
Washington, and it had to be addressed to somebody.
Q Is it fair to say that the purchase of arms is also
not World Affairs Counselors' business as well?
A That's correct.
Q Who was this letter being passed on to?
A I passed it on to Colonel North. Mr. Pena asked me
to pass it on to whoever the appropriate person was, and I
think he assumed I knew whoever the person was in the Central
Intelligence Agency that would be responsible for these types
of things, but I didn't, so I just asked Colonel North to pass
it on.
Q Do you know why Mr. Pena assumed that you would be
someone who would know the appropriate j)erspn^ at t^ C_IA to
pass along a letter of this sort?
A I just think he had watched us operate in the area
of Central American policy and had a good understanding of
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how close we were to Mr. Calero, and just assumed that we
were closely associated with the effort.
MR. DUDLEY: So the record is clear, those are your
assumptions. Are they based on any conversations you had
with Pena?
THE WITNESS: In very rough terms. I mean, not any
that I recall, specifically.
BY MR. KAPLAN:
Q The letter states that it encloses a list of
products available from a number of entities li-sted, and then
it has an attachment which is called "Price List of Items
Available. " I'll just state for the record, that the items
listed are grenades, anti-personnel mines, anti-tank mine,
NATO standards, bombs, and boots.
Is that an accurate reading?
A Yes.
Q Did you understand that Mr. Pena was going to send
youa letter that had-^ljpjg^tyQp^qf^ jyjoduct^ availability
listed?
A I understood that it was going to be military
equipment. I think we discussed rifles and boots, are the
only thing I remember specifically discussing before this
letter arrived, and it was a very short discussion. I told
him I had no idea how to — what a price tag was on something
like that, and that his suppliers would have to —
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Q Did you assure Mr. Pena that you would pass this
letter along to the appropriate people?
A Yes .
Q The last paragraph of the letter itself makes
reference to previous discussions that Mr. Pena alleges that
he had with you and states that — and I will just quote it -
- "We envision that commissions payable on the sale of any
particular product will be divided equally among the corpora-
tions involved and the placement of that product", close
quote. Do you recall the previous discussions that gave rise
to that last paragraph?
A I can recall Mr. Pena telling me that his company
had an offshore corporation. I can't recall specifically
where it was, and that he felt there would be some commission
associated with this sale. I think one or both of these
people are actually clients or personal friends of his, and
he had made an offer for splitting whatever commission had
cone to him. I didn't take it particularly seriously. I
didn't anticipate it. In fact, in all honesty I treated this
whole thing fairly casually.
Q Was it your understanding though that if commissions
were received from the purchase by the CIA of any of these
items from the companies listed by Jfc, .^aa ^hat you indeed
would share in those commissions?
A It was clear to me that he had made that offer.
'-Mil, -Pena that you indeec
iciASifinED
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I'm not sure I would have taken him up on it. I don't even
know what size the commissions would be on it.
Q Why would you not have taken him up on that offer?
A I'm not an arms' merchant. I don't care to be in
the arms' merchant business.
Q Okay .
Is it your testimony, however, that you did give
Mr. Pena the name World Affairs Counselors, Inc. because that
would not be recognizable —
A That's correct.
Q — in the domestic United States?
A Overseas. Since it is a Cayman corporation, it
would have been impossible for somebody to find out who the
principal beneficiaries were. So anybody trying to find out
who this letter was written to would not be able to do so,
and yet still the letter was written to a corporation so that
it was a legitimate offer. That way it could be passed on to
somebody and taken seriously.
" Q Is it also fair to say that you didn't want any
national business communications' name on a letter of this
sort?
Absolutely.
And why is that?
UNCIASSIRED
A Because it is not the business of International
Business Communications.
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Q Do you recall Colonel North's reaction when you
gave him this letter?
A I don't even think he took it out of the envelope.
He just said that he would pass it along, but I believe he
said that he thought that it had all been taken care of.
Q Did you have any subsequent discussions with
Colonel North about this letter or Mr. Pena's offer?
A I asked him one time whether it had been passed on
and that was after Mr. Pena had asked me if I had passed it
on to the appropriate person.
Q Okay.
What did Colonel North tell you?
A He told me he passed it on to the appropriate
person.
Q You testified on June 23rd about meetings that you
had with Colonel North on November 20th and 21st. Have you
had any contacts or did you have any contacts with Colonel
North after your meeting with him on November 21st?
- A Yes. I saw him probably within five or six days of
leaving the National Security Council.
Q Were you repre^^ted^by coMn^el_at_the time?
A No.
Q Was that meeting in the presence of his counsel?
A No.
Q Can you tell us what the purpose of that meeting
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was?
A I don't know what defines presence of counsel. It
was at his attorney's office.
Q Was his counsel in the room?
A No.
Q Who initiated that meeting?
A I did.
Q You did. What was the purpose?
A There had been newspaper articles quoting Oscar
Matsunoros and unnamed officials of the Nlcaraguan resistance,
saying that they had only gotten a few hundred thousand
dollars from the money Mr. Channell raised, and that he had
kept it all or IBC had kept it all. And knowing that we had
sent $1.7 million to Lake Resources and we had sent over $1
million directly to Calero's accounts and then the balance to
other organizations, such as Mr. Robelo's and so forth, that
didn't Jibe with reality.
And I had also read the revelation from H. Ross
P9fot that he had been asked to deposit $2 million into Lake
Resources. And it was suddenly clear to me that that account
was used for many other things ^ther than Just assistance for
the Nicaraguan resistance.
So I went to him, and the first thing I said to him
was "I hope to hell that that account was used for humanita-
rian assistance", and he said, "Oh hell, yes." And I told
IS other than Just assista
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him of my concern about Mr. Calero's statements and that it
was clear to me and that it was not clear to Mr. Calero that
the money that had gone to Lake Resources and to his accounts
had come from us. And he listened quietly to that. I asked
him whether he thought it would be a good idea for me to go
see Mr. Ca_ero and explain it to him. And his sole response
was , " I think that would be a good idea . "
And we then talked a bit about our wives and what
they were going through, and he showed me the stack of
letters behind him, and told me that he was working on his
statement to be read to the Committees on a computer. And I
left, and that is the sum of the meeting.
Q Where did the meeting take place?
In an office at Williams and Connolly.
Was anyone else present at that meeting?
No.
We also had a subsequent meeting, at which time we
were both represented by counsel in February.
- Q Did the meeting take Piace in the presence of
counsel?
A Yes, my counsel and his co'jnsel.
MR. KAPLAN: Mr. Dudley, would you assert privilege
as to the communications that took place between Mr. Miller
and Mr. North during that meeting?
MR. DUDLEY: I am prepared to let Mr. Miller
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testify with respect to that meeting, provided that it will
not be claimed by the Committee or anyone connected with the
Committees, either Committee, that doing so constitutes a
waiver of the attorney/client privilege. I am not prepared
to take a position as to whether that meeting actually is
privileged, but I am prepared to let him testify so long as
it is not considered a general waiver.
MR. KAPLAN: On that understanding which we can
represent will be the understanding of both Committees.
BY MR. KAPLAN:
Q I would like to then proceed and ask Mr. Miller
what was the substance of the discussion that took place at
that meeting?
A I had been since November putting together pretty
much by myself a report to Mr. Channell of how his money had
been expended, and had gotten to the point where being a
metier person, I recognized that it was days before it would
hit the front page of the Washington Post after its issuance,
that I thought Colonel North ^houlc^ be _at_J.ea£t apprised of
what was in it.
And I asked my attorney to discuss it with his
attorney and a subsequent meeting was set up. And he
reviewed the report briefly, and his sole concern was for the
personal safety of two individuals mentioned in the report,
and that there was only one line amended, and that single
North should be at least
UNCLASSIRED
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a-
line simply eliminated references
And we then talked about his dog, and we talked
about our wives again and our families and then we left each
other.
Q Who else was present at that meeting, for the
record?
A Earl Dudley, Ronald Precup, Barry Simon and Brenc^n
Sullivan.
MR. DUDLEY: I should state that I don't think
everyone was always present for all parts of that meeting.
MR. KAPLAN: Okay.
BY MR. KAPLAN:
Q Had you had any other contacts or conversations
with Colonel North since February, since that meeting that
you just described?
A I spoke to hin briefly by telephone before Christmas
to wish he auid his family a merry Christmas, and again we
talked about our families and Max, the dog.
We may have had one other coiiysnaiipn^ but again I
think it was just of a personal nature J |!^ a-
Q When you testified a momep": ago that you asked
Colonel North whether the funds that had been raised and
disbursed through IBC and IC, Inc. had been used for humanita
rian purposes, you said that his response was, "Hell, yes.'
Has time refreshed your recollection to amend the expletive
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that he used in response to the question?
A I would say it's ambiguous enough that it could
have been either my previous recollection or the present
recollection.
MR. KAPLAN: I'm sorry. I couldn't avoid it.
MR. DUDLEY: Only the expletives have been deleted.
THE WITNESS: He is a marine officer, you know.
BY MR. KAPLAN:
Q To your knowledge, were there any gifts or other
items of value that were given to North or his family by
anyone during the time that you have known Colonel North?
MR. DUDLEY: Did you say other?
MR. KAPLAN: No. I said by anyone.
MR. DUDLEY: I want to know whether the word
"other" was in there before the word "gifts".
MR. KAPLAN: I said gifts or other items of value.
MR. DUDLEY: I thought I heard you say were there
any' other gifts or items of value given.
MR. KAPLAN: No. I will withdraw the previous
question and ask this one again.
BY MR. KAPLAN:
Q To your knowledge, was Colonel Noftfi 'givSi^any
gifts or other items of value during your relationship with
him by anyone?
A Well, I gave him a gift but I think it was of more
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value to me than it was to him.
Q And what was the gift you gave him?
A It was a Labrador pup, and it was after the stories
had come out about his dog being poisoned. And I am a dog
lover and raise Labradors, and I couldn't stand the thought
of his children being without their dog. So I promptly went
over with my pregnant wife and delivered a beautiful little
yellow Lab pup, only to fihd out later that the dog that was
killed was about six inches tall. So I am not sure he has
ever been as grateful as I thought he would be for introducing
this monstrous 97 pound beast into his household.
Q You may have taken a liking to me over the course
of our relationship, and I know my wife would appreciate it
if you didn't deliver a Labrador pup.
A I always remember things. So I never do the wrong
thing twice.
Q Are there any other gifts or items of value that
you or any of your associates gave to North during the time
of 'your professional relatJLosahla wj.tii iLijn?
A None other.
Q Are you aware of gifts or items of value given to
North by Mr. Channell, and I will say other than the implica
tion of your testimony that North flew on a Channell chartered
plane or a Newington chartered plane to Mrs. Newington's that
weekend?
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A I think when Mrs. Newington — when we were at Mrs.
Newington's, she gave each of us a tie. I got one. I'm
pretty sure Colonel North got one.
Q Do you recall a briefcase that Mr. Channell or
yourself might have given to Colonel North at some time
during 1985 or 19867
A I remember Mr. Channell giving me a briefcase, but
I don't remember him giving Mr. North one.
Q Okay.
Have you had any contacts with Mr. Channell or Mr.
Conrad since November 19867
A Yes.
Q When was the first such contact after November?
A Mr. Channell retained IBC again in November to
assist in his relations' effort, and we continued that
relationship until April, I believe.
Q Of this year7
A Of this past year; that's right.
Q Aside from any efforts of IBC's on his behalf with
respect to that professional relationship, did you have any
discussions with Mr. Channell after November 1986 about your
respective participation in what I am referring to as the
contra funding network?
A Well, sure. I presented the report to him. He
in wnac i am rererring to
asked continually for as much documentation as could be
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provided. And I sought that documentation from the recipients
of the assistance, and I'm sure we discussed it.
Q What prompted the February 1987 report, a portion
of which was marked yesterday as Exhibit 17?
A Dan Conrad had been asking for about nine or ten
months for a full report of the 1985/86 expenditures, and
there simply was not during the period in which we were
working for Mr. Channell time to do it, since I was the
individual that would have to do 95 percent of the work
And finally in November it became clear to me that
he would need a report for tax purposes and for purposes of
talking to his own contributors, and so I worked I have no
idea how many hours, but virtually every night and all
weekends for some time mid-November probably until the report
was issued in February.
Q Did you discuss the substance of the report with
Channell or Conrad before you actually gave the report to him?
- A No.
Q You and I talked yesterday about some of the
conclusions in the report that are on page 3 of Exhibit 17.
Did you review these conclusions drawn with anyone prior to
giving the report to Channell?
MR. DUDLEY: Other than counsel.
BY MR. KAPLAN:
Q Other than counsel?
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No.
Q Were these conclusions in the report when Colonel
North reviewed the report in your meeting with him and in
your meeting with him and counsel in February 1987?
A Yes.
Q Did Colonel North comment at all about the con-
clusions that we discussed yesterday?
A He made no comment about it, but I remember
specifically his counsel saying that they took no position on
any of the characterizations.
Q Did Mr. Gomez review the report before it was
turned over to NEPL?
A I don't believe.
Q Did you discuss the conclusions drawn with him
prior to distribution to NEPL?
A I don't think so.
Q Have you discussed those conclusions with Mr. Gomez
after the issuance of the report?
A I may have, but I don't recall specifically.
Q And did you discuss the conclusions with Mr.
Channel or Mr. Conrad after the issuance of the report?
A No.
Q You mentioned yesterday that you met --
A Can I take a break?
MR. KAPLAN: Fine.
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[Brief recess . ]
BY MR. KAPLAN:
Q I believe that you testified yesterday that you met
David Fischer some time in December of 1985.
A I think I may have met him in November or some time
at the end of the year.
Q Do you recall who introduced you to Mr. Fischer?
A Marty Artiano.
Q How did you know Mr. Artiano?
A I knew Marty from the campaign. We had a casual
acquaintance during the campaign.
Q Which campaign are you talking about?
A The Reagan/Bush 1979-80 campaign. And I subsequent-
ly got to know Mr. Artiano better when he was working at the
State Department and subsequently to his leaving the State
Department and becoming a partner at Anderson, Hibey, Narheim
and Blair.
Q Did you work with Mr. Artiano at the State Depart-
ment?
A We had some contact. His position there was in the
Office of International Organizationo and AID has a fair
amount of work with the Office of International Organizations.
Q Did Mr. Artiano introduce Mr. Fischer to you for a
particular purpose, at least as far as you know?
A Yes. I tvtfita%t^i^^d A Sf Sttb^'SC either a consulting
Missm
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organization to take over the account completely or to find
somebody that would be willing to work together with us on
the account for Mr. Channell. And it was contact with Mr.
Artiano that led to the conversations with Mr. Fischer and
himself .
Q By the account, you are referring to the NEPL
account?
A All the Channell organizations.
Q Okay.
What was your interest in Mr. Fischer particularly?
A We had gotten to a point with Mr. Channell where we
were not able to increase his level of efficiency and
programs with our stature, and we needed somebody of greater
stature to accomplish that. And that was our reason for
seeking senior consultants to do that.
Q What did you learn about Mr. Fischer's background
upon meeting him?
A I knew exactly who David Fischer was before I ever
met him. He was as well known to campaign people as would
have been Lyn Notziger or Ed Meese or anybody like that.
Q What was Mr. Fischer's pos^.tion in the White House?
A He was President Reagan's personal assistant.
Q Did IBC and Mr. Fischer conclude a business
relationship some time in November or December of 1985?
A Yes. !}Mf^Mf^^?'r!iri
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Q What was the relationship that you arrived at?
A Mr. Fischer and Mr. Artiano were retained by IBC to
work on initially the Channell account, and their services
would include the arrangement of briefings for Mr. Channell
and his people with senior officials, policymakers, policy
implementation offices for the arrangement of briefings by
senior Administration officials or Mr. Channell and by Mr.
Channell to senior Administration officials and policymakers.
They were responsible from that period forward for
most of the senior-level contacts within the Administration,
Congress. They provided some advice and counsel on strategic
planning, reviewed texts for proposed programs, made recommen-
dations as to how to improve the success of the programs.
They wrote planning memoranda and at some points I think they
worked on talking points. That's all off the top of my head.
Q What was the initial financial arrangement of your
relationship with Mr. Fischer and Mr. Artiano?
A Mr. Fischer and Mr. Artiano asked initially for
$20,000 a month with a long-term commitment. It didn't take
them very long to realize how demanding Mr. Channell was, and
for them to continue the effort, they required that I
guarantee to them two years' worth of retainer, which I
agreed to do. Since that was money X would have gotten from
Mr. Channell in order to guarantee it, I left it up to them
to make calls for i^*«<iifi.tjritui.iQn.aj3d_Sver the course of the
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next six to eight months, I charged Mr. Channell sufficient
fees to be able to meet that guarantee.
Q What was Channell 's understanding as to the fee
basis that you had arranged with Fischer and Artiano?
A I told him — and I remember a conversation in my
office at my conference table with Mr. Channell — that I was
going to charge him $20,000 a month plus $50,000 a month and
he was actually, I think, kind of disturbed by that. But I
also explained to him that he wanted the level of effort that
he had outlined, that that was going to be what was required
and he accepted it and paid it out over actually I think a
period of about eight months. That may be a shorter length
of time, maybe six months.
Q Is it fair to say that you had almost daily contact
with Mr. Fischer with respect to his carrying out of the
services under your business arrangement with him from
December 1985 forward?
A I would use the term daily because it included
nights and weekends. It was an extremely demanding period of
time.
Q Did Mr. Fischer work out of your offices?
A No. For a period of time, he worked out of Mr.
Artiano 's office. He also was still living in Salt Lake
City. So he would fly to Washington, and when he was in
Washington, ■^"•"a^y"fTh b° j-'^i^j iWrJ'mmt of IBC's offices.
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Q With what regularity did you have contact with Mr.
Artiano during this same period of time, that is from
December 1985 forward?
A Initially, I would say probably daily.
Q For how long?
A I don't know, probably the first three months or
so, four months. And then my contacts gravitated more to Mr.
Fischer.
Q Did you receive bills from Mr. Fischer or Mr.
Artiano or both for payment of these monthly retainers?
A No. I left it up to them to make cash calls on us.
Since it was agreed upon $20,000 a month, there was no need
for any elaborate mathematics. I simply knew how much money
they had coming, and they were allowed to call on it any time
they wanted to.
Q When you contacted Mr. Artiano, did you contact him
at his law office?
A Yes.
Q And that would have been daily contact for at least
a period of months after and including December 1985?
A That's correct.
Q Did Mr. Artiano — strike that question.
What was the form of payment that you made to
Fischer and Artiano pursuant to this business arrangement?
A Both checks and wires
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Q How come wires?
A No particular reason.
Q Would there be wires to Mr. Fischer in Salt Lake
City?
A Either to his account in Salt Lake City or to Mr.
Artiano's account in Washington.
Q Were your checks made to Mr. Fischer personally, or
were they made to David C. Fischer and Associates?
A I don't really remember. It's academic.
Q Just so we can clarify for the record, I take it
that you made — of this $20,000 a month, did you make a
portion of that $20,000 by payment to Mr. Fischer and a
portion of that--to Mr. Artiano each month, or did you make a
lump sum payment that they split amongsti themselves?
A Initially, I made lump sum payments that they split
eunongst themselves, and then it was up to each one of them to
make cash calls. And whatever their cash call was, that is
wha^ I paid, simply that their request for payment was met by
a payment.
Q Were payments to Mr. Artiano made to htm personally,
to the best of your recollection?
A I think so.
Q Did you eveiL make any payments to the law firm of
Anderson-Hibey?
A I think I made a payment to Anderson. No, I don't
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think I have ever made a payment to Anderson.
Q Did you have meetings with Mr. Artiano during the
first month after the beginning of the relationship?
A Yes.
Q Where did those meetings typically take place?
A Well, when they were just regarding our client,
they would have been at IBC or at his office.
Q When you say "his office", you are referring to his
office at Anderson-Hibey?
A Yes. And I also attended some meetings with him
that he and Mr. Fischer had set up with officials or policy
offices, and those would have been outside our offices.
Q How long did Mr. Fischer maintain offices at Mr.
Artiano' s law firm?
I couldn't say for certain. I can't place a time
on it.
Q Did he have a separate office at the law firm?
A I don't know.
Q what was your understanding as to the relationship,
if any, between Mr. Fischer and the law firm of Anderson-
Hibey?
A I don't think there was a relationship.
Q Other than tie.^ct tjja^ hehad an office there —
A Yes . I
Q — at least for a period of time.
'£.*» that he had an o
fUSSIFIED
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Was there a time when Mr. Fischer took up an office
residence at IBC's offices?
A Yes .
Q When did that occur?
A In late June or July of 1986.
Q So that was some time around the time that IBC and
David C. Fischer and Associates entered into a joint venture
arrangement?
A That's right.
Q Do you recall what the total fees were that were
paid to Fischer and Artiano over the course of your relation-
ship with them? Well, strike that.
Do you recall what the total fees that were paid to
Fischer and Artiano pursuant to this business relationship
that was struck between IBC and them in December of 1985?
A It would have been about $480,000.
Q And do you recall when those fees were paid?
A Over the course of the next probably eleven or
thirteen months .
Q Was there a time when the fee payments of $20,000 a
month were accelerated by IBC?
A Well, they had the right to accelerate it any time
they wanted to, depending on **h*t .tbej.r_naed3_were^ It was
for me a singular commitment.
Q So that if I understand you correctly, in December
WDiWD"
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of 1985 you guaranteed to Fischer and Artiano $20,000 a month
and you guaranteed to them payment for 24 months running from
that time.
A Correct.
Q And if my multiplication serves me correct, that 24
months times $20,000 comes to $480,000. Is that correct?
A That's correct.
Q So that there was a lump sum arrangement in
December 1985 of $480,000 payable to them. Is that correct?
A That's correct.
MR. DUDLEY! I have a little trouble with the
phrase "lump sum" there. There was a total commitment to pay
that.
MR. KAPLAN! I'll take that clarification.
BY MR. KAPLAN:
Q Was there a total commitment made in December 1985
that IBC would pay Fischer and Artiano that amount, pretty
mucli regardless of what happened?
A Well, as long as they continued to work with the
client.
Q Okay. And that was part of the understanding in
your original relationship.]
A Yes.
UNCLASSIFIED
Q And pursuant to that total commitment though, as I
understand your testimony, is it correct to say that Fischer
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and Artiano had the right to call upon IBC to make payments
of amounts up to that $480,000 at any time during their
performance of services under that original business relation-
ship?
A Well, they had the right, but obviously, if they
had stopped doing the work, we would have not been eunenable
to the call.
Q Right. But assuming that they did continue to do
the work —
A Yes, they had the right to call, and they did on
occasion call for large sums.
Q If they had come to you three months into the
relationship and called on the entire $480,000, would IBC
have paid to them under the terms of their relationship that
$480,000?
MR. DUDLEY: Objection; that is speculative.
THE WITNESS: Yes. That's a hypothetical. I
wouldn't answer i^.
BY MR. KAPLAN:
Q Was there a time in which they called more than
$20,000 a month?
A I think there was at least one occasion — well,
maybe as many as two or three.
Q Did IBC pass through all the payments to Fischer
and Artiano to NEPL?
UNCLASSIFIED
355
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Do you understand what 1 am asking?
A No.
Q Was NEPL charged for Fischer and Artiano's services
that IBC paid for?
A Yes.
Q In total?
A In regards to the client relationship that we
discussed earlier, yes. There was an additional relationship
at a later point in tiroe.
Q Okay, which didn't involve NEPL?
A No. It involved IBC clients in general.
Q I see. And the $480,000 that was paid to Fischer
and Artiano under this original business relationship that
was struck in December of 1985, was that $480,000 charged to
NEPL by IBC?
A That's correct.
Q Okay .
•DJ-d you have an understanding that Fischer and
Artiano were being paid based on a number of meetings with
the President that they were able to arrange?
A No.
Q Do you know whether anyone else had that understand-
ing?
A At some point~we "actually ITeld a~meeting because
Spitz or Dan Conrad — I have forgotten which — had said
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something similar to that, and we actually held a meeting in
my conference room, in which Marty Artiano quite avidly
dissuaded them of that notion, and I remember him saying "I
have no idea how this got started but I want it to be clear
that that's not why we were brought into this." And it was
agreed that that was the case, and the meeting was ended.
Q When did that meeting take place?
A We were in our new office. So it had to be after
January .
Q
A
Q
A
Of 1986?
Yes.
What was Channell's response?
I don't think he particularly liked the direct
nature that Marty used to discuss it with him, and aside from
that, I think he was in agreement.
MR. McGOUGH: Would you mind if I interjected here
because I have the sequence I think a little more clearly.
MR. KAPLAN: Go right ahead.
EXAMINATION BY COUNSEL FOR
THE SENATE SELECT COMMITTEE
BY MR. McGOUGH:
Q There was originally the agreement for $20,000 a
month. Is that correct?
iU
A Correct.
Q There then was a meeting you had wITJT'Mr. Channell
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that you mentioned before at a conference table where you
told him that over the next six months you were going to
charge him $20,000 a month plus $50,000 a month.
A That's correct.
Q When did that meeting take place?
A It had to be in December because we were in our old
offices.
Q So you had the meeting in December where you told
him that was the arrangement. What was his response to that
offer or request?
A He wasn't happy about it.
Q I think you said December of 1986. You mean
December of 1985.
A Correct .
Q Did he ask you anything about what Fischer and
Artiano might do in exchange — or if he, in fact, were to
pay $70,000 a month? Did he ask you anything about their
capabilities?
A Your time frames are reversed because he was the
one that set the work product necessary to his program. So
he had already identified what he wanted to have done.
Q There was a time when he thought he was going to
pay $20,000 a month. Is that right?
A Initially, when I spoke to Mr. Artiano and Mr.
Fischer, we were talking, fltyjiiJ^ $20^^
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Q And did you relay that on to Mr. Channel 1?
A I think initially I did relay that to Mr. Channell.
Q Then you came back in December of 1986 and said
that for the next six months you were going to charge him
$20,000 a month plus $50,000 a month.,
A Correct.
Q And Mr. Channell wasn't happy with that.
A That's correct.
Q Did Mr. Channell ask you anything about Presidential
meetings at that meeting in December of 1986 -- 1985. I'm
sorry.
A He may well have. I don't have a specific recollec-
tion, but again you have got the cart before the horse. I
don't want to use any particular analogy.
The work product that Mr. Channell was demanding
had already been discussed prior to that meeting.
Q I understand that, and I understand that Presiden-
tial meetings may well have been discussed prior to that
meeting. But my question is: When you broached that
proposal with him in December of 1986, the proposal being
$20,000 plus $50,000 — in 1985 — wiien you broached that
proposal in December of 1985 for $20,000 plus $50,000, did he
ask in response anything about Presidential meetings?
A Again, not that I specifically recall, but Presiden-
tial meetings were pi:tth ff £^ fch% Qf e^ious discussion of the
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work product that he needed. So it is entirely possible but
I don't recall a specific exchange on it.
Q Do you recall a specific exchange involving whether
or not he would receive for Presidential meetings over the
next four months?
A I remember he wanted the President at events over
the next four months, and I think ultimately six or eight
months. But he -- yes.
Q That was at the December 1985 meeting.
A Yes.
Q And what did you tell him about the President's
availability over the next four months or six months? I
mean, did you tell him that you would have to check with
Fischer and Artiano as to whether that was possible?
A I don't recall whether I said that to him or not.
Q Did you make any response at all to him?
A Again, I don't recall the specific exchange. So I
don't recall. But again, he understood going into that
meeting that he was requesting as part of his work product
meetings with the President.
Q I understand that. But I sm focusing on the
December meeting, and all I want to know is whether you have
a recollection as to that meeting of Mr. Channell asking in
response to your proposal for $70,000 a month about the
President's availability for meetings over that same time
\mmm
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period, over the next four to six months?
A I don't have a specific recollection.
Q Did Mr. Channell agree to that amount at that
meeting, or did you have to go back and get further informa-
tion from Mr. Artiano and Mr. Fischer?
A I recall him agreeing at the meeting. In fact, I
recall him leaning on my fireplace and saying he was not
happy about it, but that he was willing to pay it.
Q Did he indicate what he expected in exchange for
the additional payment?
A I don't remember a specific exchange about what he
expected for the additional payments.
Q Did you come away with a sense that he expected any
additional effort on the part of Mr. Fischer or Mr. Artiano
or any tangible work product from that?
A Yes, but it wasn't any different than the same
expectations going into the meeting.
Q So you don't recall him having any additional
expectations for the additional $50,000 per month?
MR. DUDLEY: "Additional" may be wrong here'. It is
escalated $50,000.
MR. OLIVER: He used the word "additional" earlier.
MR. DUDLEY: I know he did and I let it go by and I
shouldn't have.
BY MR. McGOUGH:
UNCLASSIFIED
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Q I am trying to understand you had struck a deal in
November to provide certain services, in November of 1985 to
provide certain services for $20,000 a month.
A Right.
Q Within one month you come back —
A In probably less than one month.
Q In probably less than one month you come back and
say, "No, the price is now $70,000 per month." I'm trying to
get at whether in exchange for that increase in at least
monthly installments or that compression of the money whether
Mr. Channell spoke in terms of additional results or addition-
al effort or additional work product from Mr. Fischer or Mr.
Artiano. Or did he say, "No, that's okay; I will pay $70,000
for what I originally thought we were going to get for
$20,000."
A Again, counsel, I am not trying to be evasive but
the meeting was predicated on the fact that there was a great
increase in the amount of effort that Mr. Channell expected
over the next six months. And it was my requirement that he
pay this extra money associated with that effort.
Q So it was Mr. Channell who had set the predicate
for the meeting as being additional effort over the next six
months?
A Oh, yes.
Q What were the additional efforts that he was asking
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liNCUSSIFlEO
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for over the next six months?
A Well, initially when we went to Fischer and
Artiano, first of all, we had to retain them to even begin
the discussions. So that I remember clearly. And initially
they thought they were doing mostly advice and counsel. When
it became clear early on in their first meetings with Mr.
Channell that he had a very long agenda with a lot of work
elements associated with it, that required a lot of time on
their part and a lot of contact with very senior officials
and their credibility on the line and so forth. That's when
they suggested that they were going to have to have a two-
year commitment from me, and I agreed to that.
This is all within probably one to three weeks.
Q All right. This was before a deal was struck for
$20,000 a month for two years.
A At that point, the deal was struck for $20,000 a
month for two years.
Q We're at that point.
A Right.
Q I'm just trying to follow the sequence through.
The coming up on this meeting in December of 1985, Mr.
Channell made additional demands on them.
A I guess my problem is that I am looking at a
maximum of three weeks, probably about a two-week period
where it became clear that the ampuat.of .^ork that Mr.
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Channell was requiring was greatly in excess of what he had
conveyed to anyone before.
Q I know we have to focus on that. What I am trying
to get at is the difference between the work he had conveyed
before and the work that now led up to this December 1985
meeting where the payments were compressed. What was the
difference in what he was asking before?
Before all he was asking for was advice and counsel,
Advice and counsel on what?
On his programs, just on the substance of his
And it didn't involve Executive Branch liaison?
No.
It didn't involve setting up meetings with the
A
Q
A
programs
Q
A
Q
President?
A No.
Q After in that two to three-week period leading up
to the December 1985 meeting, he changed or he increased the
demands upon them. Fair enough?
A 1 will give you that if you don't keep your list
only two items long.
Q Fine. But he made additional demands.
A Right.
Q And was ^h®|Q¥S*iCg^% JS^V^rfWW^®^ 1985 meeting?
A Right
mSKET
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Q And at the December 1985 meeting one -- or leading
up to the December 1985 meeting, one of the additional
demands was Executive Branch liaison?
A That's correct.
Q And one of the additional demands was assistance in
setting up meetings?
A That's correct.
Q And there were other demands as well.
A A tremendous number of other demands.
Q A tremendous number of other demands . And in
exchange for those additional efforts you asked for an
increase in the monthly payments from $20,000 a month to
$70,000 a month over the next —
A Correct.
Q — six months. And in that context was there any
discussion of the number of Presidential meetings that Mr.
Fischer or Mr. Artiano might be able to set up over the
coucse of the next four to six months?
A I don't remember a specific exchange about the
number of Presidential meetings. I recall that Mr. Channell
was anticipating having af .i€>^5f. orie^\ieiit;_4 jnQflth like the
one he had in January.
Q And did he inquire whether or not the President --
whether or not Mr. Fischer or Mr. Artiano might be able to
arrange for the presence of the President at one or more of
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those events which would work out to one or more a month over
the next six months?
A I don't recall a specific exchange as you have just
characterized .
Q But the schedule for the events over the next six
months was certainly a topic of conversation, was it not?
A Mr. Channell had anticipated having one of these
events one a month for the next six — originally four months
and then six months.
Q And he wanted the President to attend those, did he*
not?
A If possible, yes.
Q And at some point you would have discussed, would
you not, with Mr. Fischer and Mr. Artiano their ability to
arrange for the President's presence at those meetings.
Correct?
A I think you have to rephrase your question.
_ Q I guess what I am saying is you would have asked
thm, "Hey, Marty, hey, Dave, Channell plans a series of
events over the next six months. Is there any chance you
could have the President attend" or -omething to that effect.
A I think it was more a matter of us laying out or me
laying out for Marty and David the total agenda that Channell
had over the next six months, and they felt confident that
they could help meet it.
UNCUSSIRED
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Q And that agenda included, at least ideally,
arranging for the President to attend Channell's events.
A Well, there were a lot of ideal items on it, and
several which never happened.
Q I understand. But one of the items would have been
that.
A Yes.
Q And you would have discussed those ideals with Mr.
Artiano and Mr. Fischer, would you not?
A We would have discussed the agenda in general . I
don't think I would have ever questioned whether or not they
could deliver on the agenda if they said they could.
Q But they would have indicated that they could
deliver. You said you wouldn't have questioned them if they
said they could. Did they indicate that they could do that?
A You and I have used "if" and "would" about ten
times in the last three sentences, and I am telling you I
donjt recall a specific exchange, and I just want to leave it
at that. I mean, I don't think I would have challenged them
on whether or not they could deliver on something. I don't
think I would have ^sked them^Decy.tica]J.v whptjier they could
deliver on something UNbLAOoll IlU
Q Would they have told you about their capabilities
as far as bringing the President to Mr. Channell's events?
MR. DUDLEY: I object to the form of the question.
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I will let him answer did they tell you.
BY MR. McGOUGH:
Q Did they tell you?
A I don't recall them specifically telling me that.
MR. McGOUGH: I think I have pretty well played out
that.
MR. KAPLAN: I just have two follow-up questions on
that area, and then I want to move on.
EXAMINATION BY COUNSEL FOR
THE SENATE SELECT COMMITTEE (Resximed)
BY MR. KAPLAN:
Q Did Mr. Channell tell you in this meeting that
occurred in early 1986 how he arrived at the understanding
that he apparently had arrived at that he would be paying
$50,000 for meetings that could be set up with the President?
A I don't think what we were trying to dissuade him
of was that he was paying $50,000 a meeting. What we were
trying to dissuade him of was that the sole reason he had
hired Mr. Fischer was to set up meetings with the President.
Q Did Channell tell you how he arrived at that
understanding?
A No.
Q How did you learn that Channell was holding this
understanding of hi § Jipgii»§ss_ relationship with Fischer and
Artiano?
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INCUSSIHED
363
A I think it was an errant comment made by him to
either Mr. Fischer or myself or Mr. Artiano.
Q Okay. And that's what gave rise to the meeting?
A Yes. It was an attempt to nip it.
Q And you described the meeting earlier in your
testimony here today.
A Yes.
Q Let ' s move on .
Do you know a Richard Secord?
A Well, I met him on the street one time and I talked
to him on the phone three times .
Q When did you meet him on the street?
A About a week ago.
Q How did that meeting come about? Was it a chance
meeting?
A It was very chance and it was a simple handshake
and a wish for good luck to both of us.
Q Did he know who you were when you introduced
yourself?
A I don't think he recognized me immediately but
shortly I think it dawned on him who I was.
Q Did you "13^4 thi-V#il ^^nFJiFt9^ §^9SP^^'-^ around
Dupont Circle? UsiyLM^
A Yes. I have spoken to him on the phone, as I told
you in past meetings, I guess, about two or three times.
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WUSSIFIED
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MR. KAPLAN: Let the record reflect that IBC's
offices are near Dupont Circle as are General Secord's
t
counsel's offices.
Off the record.
[Brief discussion off the record.]
MR. KAPLAN: Back on the record.
BY MR. KAPLAN:
Q In what context did you have phone conversations
with Mr. Secord previously?
A Well, I didn't know it was Mr. Secord at the time
during the al-Masoudi business. I eventually got to the
point —
MR. KAPLAN: What I would like to do actually is to
go on for about five more minutes and then take about a ten-
minute break.
THE WITNESS: The supposed oil contract needed to
be checked out and I asked Colonel North if there wasn't
somebody that couldn't in an official capacity check it out.
And he gave me a number in Northern Virginia and said, "Call
this and ask for Mr. Kopp", and I did, and they took my name
and number and then called me back, ■?r rather he called me
back. I gave him the account number or the contract number,
and he called me back in about a week-and-a-half or two weeks
to tell me that the contract did not exist.
BY MR. KAPLAN:
IINCIASSIflEO
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iCUSSIFIED
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Q Do you recall the third phone conversation you had
with Mr. Kopp?
A I called him about — well, no, those were the only
ones I had with Mr. Kopp. I had one other phone conversation
with him about a month ago.
Q What gave rise to that conversation?
A I had a film idea and I wanted to discuss it with
him.
Q Why did you discuss General Secord to discuss the
film idea with him?
A Well, I figured with he on one side of this network
and me on the other, we would pretty much cover the details
associated with it. It has gone nowhere than a phone conversa-
tion.
Q Is it an idea that relates to some of the activities
under investigation by these Committees?
A Of course.
MR. KAPLAN: I am going to ask the reporter to mark
as Exhibit Number 25 a copy of a page of notes that was
produced by your counsel to us.
(Where'jpon, Deposition Exhibit
Number 2 5 was marked for
identification. )
BY MR. KAPLAN:
Q Can you identify those notes?
IIILASSIFIED
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UNCUSSIRED
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A Yes . That is from a notebook that I kept during
the al-Masoudi period.
Q Okay. Do you recall the context in which these
notes were written?
A It was a conversation with Mr. al-Masoudi.
Q Did Mr. al-Masoudi tell you the information that is
contained in the item numbered 1, which says "Paid order to
Credit Suisse", and then it has the name Kopp underneath?
A Yes.
Q Did Mr. al-Masoudi know this Mr. Kopp?
A He met him in Geneva.
Q And was this a request, and does this note reflect
a request from al-Masoudi for you to send some money to him
in care of Credit Suisse and Mr. Kopp?
A No.
Q Do you recall what this note reflects?
A Barely. It's vintage al-Masoudi. It's some bright
idea he had to give Mr. Kopp some money.
Q Did he tell you what he was going to give Mr. Kopp
some money for?
A No, but I am assuming that he had put two and two
together and assume that Mr. Kopp was in some way related to
Mr. North and the Nicaraguan resistance.
Q When did you learn that Mr. Kopp was the same
person as General Secord:
" tic
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ILASSIRED
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A I think it was the same article as the H. Ross
Perot revelation.
Q That's in December of 1986.
A Yes, but it was about that period anyway.
Q Were you aware at the time that you were handling
some transactions between IC, Inc. and Lake Resources, and
that Mr. Kopp had an association with Lake Resources?
A Well, I think from the al-Masoudi business I had
some inkling, but nothing substantial or specific.
Q Did Mr. Kopp's name ever come up in conversations
between you and Colonel North or you and anyone else in
connection with your contra funding activities?
A Well, subsequent to the checking out of the oil
contract, Colonel North said that he sent somebody to see the
real Ibrahim al-Masoudi in Saudi Arabia, and I believe he
told me it was Mr. Kopp.
Q Any other times that you recall his name being
mentioned in connection with your contra funding activities?
A I'm not remembering any right now.
Q How well did you know William Casey?
A He fired me one time. He Furloughed me, as you
were so nice to put it before.
Q Aside from that, how closely did you work with him
during the campaign, that is the 1980 campaign?
A In 1980, not very closely.
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ONCLASSIHED
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Q Did you have any subsequent dealings with Mr. Casey?
A No, not directly.
Q What dealings would you have had with him possibly
indirectly?
MR. DUDLEY: I object to the form of the question
THE WITNESS: Well, there was an indirect dealing
and that was that Mr. Fischer set up a meeting between Mr.
Channell and Mr. Casey to discuss an idea that Mr. Channell
had for doing a film on the Central Intelligence Agency.
BY MR. KAPLAN:
Q And I take it to your knowledge nothing ever
materialized about that film idea?
A No. I shy away from films about the Central
Intelligence Agency.
Q You described yesterday some contacts and communica-
tions you had with a fellow named Roy Godson.
A Yes.
Q Are there any other contacts you had with Mr.
Godaon than the ones that you described yesterday?
A Not that I had, but I think Frank had some brief
contact with him at about the time they produced their book
on Soviet disinformation.
Q Have you ever had any contact with Vice President
Bush?
A I have met Vice President Bush
ntact With Vice President
ICIASSIRED
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Q Any substantive contact with him?
A Well, Mr. Conrad, Mr. Channel 1 and myself went to
see Vice President Bush. Mr. Channell requested the meeting.
Mr. Fischer, Mr. Artiano and myself set it up. I went; we
were presenting to Vice President Bush a survey of the Select
500 which is a Channell survey system of senior contributors
to try and get some sense of the conservative activist
heartbeat, senior conservative activist heartbeat. And we
went and presented that to him, and also described the
Central American Freedom Program and suggested that he might
try and attend one of the briefings. And he said that if it
fit his schedule, he would. We subsequently tried and it
didn't fit his schedule, so he didn't.
Q Who arranged the meeting for you with Vice President
Bush?
A I think it was a collective effort of myself, Mr.
Fischer and Mr. Artiano.
Q Have you ever met Donald Gregg?
A No, I don't think so.
Q Have you ever had any dealings with Felix Rodriguez?
A No.
Q Did you have any knowledge of the Iranian arms '
sales prior to public disclosure of thpsfi-Sflies?
A No.
Q Did you have any knowledge of what is commonly
disclosure of those sa^s
UNClASSiFlED
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UNCUSSinED
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referred to as the diversion of proceeds from those arms'
sales to the contras prior to public disclosure of that
activity?
A Unfortunately no.
Q Did you have any knowledge of any third-country
solicitations that took place by United States Government
officials prior to the public disclosure of those solicita-
tions and aside from the reference to third-country solicita-
tion to which you testified back on June 23rd?
A Of June 2 3rd?
Q Do you recall on June 23rd you testified that in
your conversation with Colonel North on Friday, November
21st, he made a reference which you didn't understand at the
time, that he had given one to Secretary Shultz and Secretary
Shultz hadn't done so well on it. Do you recall that
testimony?
A I do.
Q Aside from that conversation, did you in 1985 and
1986 have any knowledge of any third-country solicitations —
A No.
Q — made by the United Stat'^s Government personnel?
A No.
Q Did you have any knowledge of any third-country
solicitations on behalf of the contras made by anyone during
1985 and
'"" yilMSiREi
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UNCUSSIFIM
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MR. DUDLEY: To the extent that the al-Masoudi
effort could be considered a third country —
MR. KAPLAN: Why don't we take a break here for
five minutes.
Off the record. )
[Brief recess. ]
MR. KAPLAN: Let me ask the reporter to mark as
Deposition Exhibit 26 a copy of what purports to be two
telexes from you and Mr. Gomez to an Anthony K. Devine in the
Cayman Islands.
(Whereupon, Deposition Exhibit
Number 26 was marked for
identification. )
BY MR. KAPLAN:
Q I'm just going to ask you if you could briefly tell
us for the record what gave rise to the two telexes that are
represented by Exhibit 26. ,
A I went to see Colonel North after the Hasenfus
plane was shot down, and, as I recall, he was pretty franti-
cally working around the office, and I sat at the conference
table for some time, and I got in one question, which was:
Was that one of our P^cftfft/IWpnknaka&aj^jJie planes that
IfflE!
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uNcussra
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NEPL had raised money for? And he said, "Sure was", or
something to that effect; I have forgotten exactly what it
was he said, but his answer was affirmative.
And he was talking to somebody on the telephone,
frantically trying to find a way to find an American citizen
to give $10,000 to the United States Embassy to reimburse
Consular Affairs to bring the bodies of Mr. Walker and the
other individual back to the United States. There are
usually — I am aware of this because of my work at AID --
there are usually mortuary responsibilities that are absorbed
by the Consular Affairs Office in the Embassy, and the
individual family is responsible for reimbursing it.
And I looked at him and I said, "Why are you going
through all of this pain and aggravation? Why don't you just
give me the account number and I will transfer the money from
IC, Inc.?" And he thought for a second and he said to the
person that he was talking to on the phone, "I'll call you
back." And it just hadn't dawned on him to do it. So he
called back and asked who the money should be sent to.
I don't know who he was talking to on the other
line. It may have been this Mr. Wal'cer. And this is the
information that he got. I went back and sent a telex that
night or the next day, and he then called me on the phone and
said, "Has that transaction taken place yet?" And I said, "I
have sent the te^^piqi l^^^d^)^ j^^^a^Xdl* you pull it back?"
DNCUSSIflM
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UNCLASSIFIED
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iuulUi raroKTiNa co . inc.
507 C Strett N E 2 5
Wuhiniton. D C 2000Z
(20!) M&-6M«
And I said, "I think so." And he said, "Please cancel it."
Q Did he tell you why he wanted you to cancel the
telex?
A No.
Q Did you ask him why?
A No.
MR. OLIVER: Can I follow up just on that particular
thing?
Mr. Miller, after you cancelled that telex, did you
notify Mr. Walker either directly or indirectly that it had
been cancelled?
THE WITNESS: I never discussed it either way with
Mr. Walker. I never talked to Mr. Walker about it.
MR. OLIVER: Did you discuss with anyone else
contacting Mr. Walker?
THE WITNESS: I don't believe so. No, I didn't.
MR. OLIVER; You didn't instruct anyone to notify
the State Department or Mr. Walker that the telex had been
cancelled or that other arrangements had been made?
THE WITNESS: No.
MR. OLIVER: Thank you.
BY MR. KAPLAN:
Q Did the initials lOtfH ^*fqr .io^aji^ aircraft?
A I believe so.
Q Do you know what kind of aircraft they refer tO'
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(202) Mi-666«
WNCWSSIflEO
374
A C-9, I really don't know what configuration it is.
Q Do you recall a conversation with Colonel North in
the summer of 1986 in which you would have informed him that
a C-9 was on standby?
A A C-9 was on standby?
Q Yes.
A I don't think so.
Q Would he have given you any information to that
effect?
A
Q
A
matter
Q
A
Q
A
When? February?
Summer of 1986.
It may have been in regards to the al-Masoudi
No, in 1986.
Oh, 1986?
Right .
It could have been one of the heavy-lifting
operations - There was one point when he had an extremely
urgent need for money and nothing was moving until the money
got there, and that may have been the instance in which --
MR. KAPLAN: Okay. I am q-.^ing to ask the reporter
to mark as Exhibit 27 a copy of a document that was produced
to us by your counsel. It is typewritten, and it is headed
at the top "Statutory Provisions on Contra Aid".
(Whereupon, Deposition Exhibit
UNCLASSIRED
380
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(U2| M«-««66
UNCLASSIHED
375
Number 27 was marked for
identification. )
BY MR. KAPLAN:
Q Do you recognize this document?
A Yes.
Q Can you tell us what the document is?
A I got this document since Colonel North left the
NSC.
Q Do you know who prepared it?
A I don't.
Q Where did you get the document from?
A I honestly don't remember. I may have gotten it
from Frank Gomez .
Q Did you ask Gomez for the document?
A No, but lots of times when he had something, he
just provides it to me if he knoira I'm working on it.
Q And for what purpose did you receive this document,
or for what purpose did you ask for this document?
Let me back up a minute. How did this document
come into your possession?
A I don't remember specifically how it came into my
possession. My use of it was general information. I was
trying to produce a time line for Mr. Channell's ads, and I
needed across the bottom legislative landmarks and Administra-
tion policy landmarks, and ^|&>¥>A'% tbaX.'^ vtldt-I_used this
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IMLISI tFUWIWO CO.. MC.
iO'CSotn. NE. 2 5
Wulunroa. D C n)002
(202) iti-ttU
UNCLASSIFIED
376
for. I produced that in January, I think.
Q Okay .
And is it fair to characterize the document as a
description of the variety of statutory provisions dealing
with contra aid or prohibitions of aid to the contras by the
United States Government?
MR. DUDLEY: I object to the form of the question.
I think the docximent speaks for itself, and I'm not sure he
is competent to answer the question framed in those terms.
BY MR. KAPLAN:
Q What did you consider? What kind of information
did you consider this document to provide you with?
A Items of note in the legislative process associated
with aid to the Nicaraguan resistance.
Q Did you have any knowledge of hostage rescue
efforts, that is rescue efforts of the hostages held in
Lebanon prior to the public disclosure of some of those
hostage rescue efforts during the course of these investiga-
tions?
A Yes.
Q First, I am going to ask y^ru whether you were ever
asked to provide any money to extricate the hostages that
were held in Lebanon?
A I was asked to provide money that was used in an
effort to extricate hostages from Lebanon.
ilNP mm
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(202) HA^tU
mUSSIFIED
377
Q why don't you tell us first what knowledge you had
of any hostage rescue efforts prior to their public disclosure
late last year?
A In the summer of 1985 when I began working with
Ibrahim al-Masoudi on this oil contract that was to provide
assistance to the Nicaraguan resistance, I flew to Fresno,
California for meetings with Mr. al-Masoudi. And while I was
there the TWA hostage crisis unfolded in Lebanon, and Mr. al-
Masoudi immediately offered to assist in securing the release
of those hostages. He gave me a fair amount of information
which I passed on to Colonel North by telephone. Colonel
North indicated that the information seemed a track. "Track"
is a word of art; it seems to be associated with activities
that Colonel North conducts .
And as the crisis unfolded, al-Masoudi began to
broaden his offer to help at that point five hostages held in
Beirut by terrorists. And all the information I got from al-
Masoudi — whether it was names, places or numbers or
whatever — I tried to pass those on as often as possible
daily to Colonel North, and in one instance to the Task Force
that was set up at the Federal Bureau of Investigation for
the TWA crisis.
Q How did you know about the Task Force that had been
set up at the FBI?
A There was aiai^fSkef if oJeyant information that al-
383
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Masoudi had, and they wanted to discuss it with him. And I
don't know whether North -- I don't know who told who to do
what, but I was told to call the Task Force, and they set up
a meeting with al-Masoudi in Houston, I believe.
Q Do you recall who you spoke to at that FBI Task
Force?
A I don't remember the agent's name, but they
certainly would have records of it. They sent field agents
to interview al-Masoudi in Houston.
Q Did you attend those interviews?
A No.
Then when we went to — when al-Masoudi and I went
to London and^^^^^^^B al-Masoudi had made an offer while
we were ^^^^^^^B^° ^^ ^^^ help in some form of a rescue
effort that the DBA agents were involved in, and it required
on one occasion $15,000 and on another I think $5,000 or
$10,000. And I transferred that money initially, the $18,000
in travelers check sent by DHL Courier, and subsequently the
other monies, I think, were transferred via the American
Express offices in Geneva.
Q What DBA agents are you referring to? Can you tell
us their names? ^^^^
A Well, the only one I remember is^^^^^^^^^Hwho
flew with us to London, and then flew onto]
Q When you sent travelers checks to support the
MMPI ACCIPCn
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J79
operation, who requested the money?
A Al-Masoudi requested it. I discussed it with North
and he approved me of sending it.
Q What were the source of funds for those traveJ*^^
checks?
A That was money that had been provided by NEPL
Q Was Mr. Channel 1 or Mr. Conrad ever told that *°™®
of the money that they provided was used for hostage res'-"®
efforts?
A No.
Q You referred, I believe, to approximately $18 ^''^O
worth of travelers checks that were sent by DHL Courier ^H
|. Were those sent toward the end of August of 19"^'
A I think that's correct.
Q Was there a later traveler check transfer alac* ^V
DHL Courier to al-Masoudi of $5,000?
A Yes.
Q Would that have occurred early in November 19C^-
Or did that occur early in 1985?
A There was a transfer, I think, in November th*^
wasn't completed. He never picked them up because he w** ^"
jail.
yNMSinEi
Q November 1985?
A I have forgotten exactly when that pick-up wa^' ''^'-
we got back $4,500 of that because he had been arrested* ^""
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it was at the time of the Summit. So I think the Summit was
in November.
Q Do you recall having filed a Treasury report form
nonetheless for that transfer?
A Yes.
Q Was there also a transfer about five or six days
later of $9,000 of travelers checks by DHL Courier to al-
Masoudi?
A I don't remember through DHL.
Q Okay .
Does it refresh your recollection if I told you
that we have from the Department of Treasury the various CMIR
filings that you made? That's currency and monetary instru-
ments reports' filings to what you have testified earlier.
And they show $18,500 on August 30th by DHL Courier to al-
Masoudi, 35,000 again travelers checks on November 1 by DHL
Courier to al-Masoudi, and $9,000 again travelers checks by
DHL Courier to al-Masoudi on November 6, 1985?
A Yes.
MR. DUDLEY: Do you understand his question?
People are frequently confused refre'shing recollections. The
fact that he has got a |i:Hl(|]A|th||t^pmp|r^t^fe^doesn't mean
that you remember it.
His question to you is: His having told you about
the record, do you now remember it?
tUMSSIFIED'
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381
THE WITNESS: I remember that we filed three forms.
BY MR. KAPLAN:
Q Were those checks all sent at al-Masoudi's request?
A Yes.
Q Was each transfer of travelers checks to which you
have just testified approved by North?
A Yes.
Q I am going to take you back to your initial
dealings with al-Masoudi. What did he propose to you in
terms of the business venture?
MR. DUDLEY: As a starting question, I am not
wildly enthusiastic about that one. My problem with it is
that I am not sure that the first proposal is accurately
characterized as a business venture. There are later
proposals I think that are more accurately characterized that
way.
MR. KAPLAN: I will withdraw that question.
BY MR. KAPLAN:
Q I believe that you testified earlier that your
first meeting with al-Masoudi occurred some time in April of
1985, and that he had been referred "--o you by Colonel North.
A Actually, I think I testified that it was early in
April or late in March of 1985.
Q Okay.
A We had two meetings with him, the second where he
JNCUSSinED
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signed this letter.
Q Did you meet with al-Masoudi shortly after he had
been referred to you by North?
A
Q
meeting?
A
I think it was the same day.
Okay. Did someone accompany al-Masoudi to that
Kevin Katke.
Q How would you describe Kevin Katke?
A You mean, what was his role in the meeting?
Q Who is Kevin Katke?
A Kevin Katke to my understanding at that moment was
a business agent of al-Masoudi.
Q Have you come to any other understanding as to what
Kevin Katke does?
A Well, I was told by Colonel North that he had
attempted to enter in the Central Intelligence Agency and had
been rejected, that he was unreliable because he tended to
talk about people whom he had no real connection with or no
right to claim a connection with, and sort of an Intelligence
community gap line.
Q During your initial meetings with al-Masoudi, did
he tell you what his interest was in meeting with you?
Al-Masoudi 's?
UNCLASSIFIED
Did al-Masoudi tell me what al-Masoudi 's interest
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was?
Yes.
UNCUSSIFIED
A Yes.
Q What was that interest?
A Well, it was a little difficult to understand at
first because al-Masoudi was speaking pigeon English and
Katke who doesn't speak Arabic or whatever, Farsi, was
translating. So it was a very unusual circumstance and it
made it a very difficult meeting. It probably lasted an hour
and it could have lasted five minutes. But basically, al-
Masoudi held himself out as the Prince of Jedda, Ibrahim al-
Masoudi, Senior Saudi prince, and he had a royal family
allotment oil contract, of which he wanted to donate $14
million in the proceeds to the Nicaraguan resistance. And he
asked if we could assist him in doing that, and we said yes.
Q What did you understand the form of your assistance
to be?
A I didn't really know at that point.
Q And what did you come to understand that the form
of your assistance would be?
A Well, I discussed it subss'juently with North, and
we decided to have me meet him the second time, and to have
him make whatever the formal offer was, and the second time
he came to see me, I suggested to him that he not bring Mr.
Katke, and he agreed.
UNCUSSIFIED
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UNCLASSIFIED
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And this time he brought with him a gentleman whom
he introduced as his attorney. The gentleman gave me a
business card that indicated that he was President and
Chairman of the Board of the William Penn Bank in Philadel-
phia. And Katke had told me in a telephone conversation that
Mr. al-Masoudi was attempting to buy an interest in this
bank. So that was pretty good bona fides to show up with the
Chairman of a bank in Philadelphia.
Q Did al-Masoudi propose a business relationship at
that second meeting?
A He proposed a contract letter which he dictated in
Arabic to my secretary who spoke Arabic, and she translated
it into English, and it called for a total of $15 million to
be paid to IC, Inc. And again the name IC, Inc. was chosen
at the conference table at that moment.
I hadn't been to the Caymans; I hadn't selected a
name. And the increase of $1 million was subsequent to a
conversation with North where I indicated that Frank and I
were willing to undertake this, but we weren't about to risk
life, limb and professional reputations without some compensa-
tion for it, and we were going to require that this individual
pay an additional $1 million.
And he agreed to that. So the subsequent contract
from al-Masoudi to us said enough liftings in order to equal
$15 million. It was a fairly
mmmB
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UNCLASSIFIED
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Q Was the understanding that $14 million would go to
the Nicaraguan resistance and $1 million would go to you and
Mr. Gomez?
A That's correct.
Q What was your understanding at that time or shortly
thereafter as to the nature of services that you would be
called on to perform?
A I can't put a specific finger on them, but al-
Masoudi was a very demanding individual. He called every 15
minutes with a new problem. He required us to carry the bair
in meetings with people who spoke English and to handle the
financial transactions.
Q If you can, explain briefly what the nature of
these transactions was intended to be. You mentioned an oil
contract worth $14 million, and I am not —
A Well, the contract was —
Q I was going to say that I am not familiar with the
way oil gets sold from Saudi Arabia.
A I have to tell you, counsel, neither am I.
Q Okay .
A After all of this, I still have no idea how it is
really done.
Q What I am curious about is how was this $14 million
going to be generated?
A Well, apparently — and this was the reason for the
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Chairman of this William Penn Bank, unbeknownst to us prior
to this meeting — they were going to be responsible for the
financing of this contract. And according to al-Masoudi, the
financial end of the transaction is the one that pays out the
commissions or associated fees.
The actual money that he was supposed to get from
it was quite a bit more than $15 million, a certain amount of
money — I don't know, $60 or $70 million.
Q Was the expectation that you would market this
contract?
A No, not initially. What happened was that subse-
quent to that meeting, he then called and told me that Mr.
Katke had been in charge of marketing and failed. And he had
asked if we could assist him in marketing the oil contract.
I didn't have anybody else to turn to. So I agreed that we
would try and do that, and I contacted my stockbroker and
asked him how it was done. He suggested that his firm wasn't
involved in that type of transaction, and suggested another
brokerage firm, Merrill Lynch.
I got in touch with the Merrill Lynch commodities'
brokers. They told me how an offer to sell is written up. I
produced it for them. They then put me in touch with a
couple of brokers who then asked the appropriate question,
which was what is the contract number, something al-Masoudi
was unwilling to give them for a whole host of reasons, which
UNCLASSIRED
392
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he claimed all to be legitimate. I had no way of knowing
whether they were or weren't.
And he then subsequently called and told me that
the time had expired on his oil contract and that the deal
was off. And I then in a very short period of time later got
another phone call from him, and he told me that he had
gotten a new oil contract and, to prevent the problems that
had actually gone on before, he had actually got it in the
name of International Business Communications.
I wasn't any further along in my understanding of
how to do oil contracts, but in the interest of helping the
resistance, we accepted the fact that it was in our ncune.
And I flew out to Fresno to meet with him to try and get some
more information on it. And while I was in Fresno, I
participated with him in several phone calls and he sent
repeated telexes and offers to sell to different refineries
and so forth and so on. And I was an observer during most of
that period.
Q Just so we can clarify for the record. When you
talk about marketing an oil contract^ is that the same thing
as selling oil to someone?
A Precisely.
ment? Precisely?
THE WITNES
MR. DUDLEY: Are you sure you can make that state-
: You said when ''^i talk about."
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MR. DUDLEY: Oh, okay.
[Laughter. ]
MR. KAPLAN: I was just asking for Mr. Miller's
understanding.
THE WITNESS: It was a wonderful day, sitting in
front of FBI agents, trying to explain to them that I had no
idea whether anything that was said to me before is truth or
fiction.
BY MR. KAPLAN:
Q Was the idea that the prince could deliver on some
oil, and that you and he were going to attempt to find
purchasers of that oil, and that some of the proceeds from
the sale of that oil would be given to the resistance, to
support the resistance, and $1 million of the proceeds from
the sale of that oil would be paid to IBC?
A I'll accept the entire litany except for the first
item. It was his oil contract, supposedly under Saudi Arabian
law it belonged to him, it was his oil, and so what was
represented was the profit was about 60 to $70 million to him.
Q The profit of 60 to $70 million was to him. He
could deliver on the product, that i3, the oil, at least that
was his representation?
A Correct.
Q $14 million of the profit was going to go to the
contras through IC, Inc.? •fi'fiii
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Correct.
ICLASSIFIED
389
Q And $1 million of the profit was going to go to IBC?
A Correct.
Q Okay. Would it refresh your recollection as to
your initial meeting in Fresno, if I told you that the
Committee has documents indicating telephone calls from you
to Colonel North, from a number with the area code 809, which
I believe is Fresno's area code, in early May of 1985?
A That's probably my first meeting.
MR. DUDLEY: First trip to Fresno?
THE WITNESS: First trip to Fresno, right.
BY MR. KAPLAN:
Q Was al-Masoudi referred to by any code name between
you and North?
A I called al-Masoudi "Jewel." He wore a ring that
had 17 dieunonds on it, seventeen one-carat diamonds, so I
called him Jewel.
Q Did North refer to al-Masoudi as Jewel, at least in
conversations with you?
A With me, yes.
Q Did you keep North regularly apprised of your
dealings with al-Masoudi? ^^
A You bet.
Q You kept him apprised of your dealings with al
Masoudi, both with respect to this marketing of the oil
audi? ^ .«. . .u.a ^ H^
mmm
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UNCLASSIFIED
390
contract and with respect to al-Masoudi's information about
the location and possible release of the hostages held in
Lebanon?
A That, and in addition to that, a gold contract
which he began to try and supplement his failure to deliver
on the oil contract, and also, his description of himself and
other individuals associated with the Saudi Arabian nation,
and I hoped that it could be checked out by somebody who knew
what they were talking about.
Q You travelled to England in the summer of 1985 with.
al-Masoudi and with a DEA agent?
A That's correct.
Q Did you go on, in that trip, from England^^HB
ith al-Masoudi?
Yes.
What was the purpose of that trip?
To finalize the oil contract, and the gold contract,
when did you begin to suspect al-Masoudi's
A
Q
A
Q
bonaf ides?
A Well, I spent a whole weekend in the library,
shortly after I met him, at the McKelden Library, at Univer-
sity of Maryland looking the guy up. The biggest problem you
have with the Saudi royal family is that there are no books
with pictures of any of them. They kind of like it that way,
apparently.
WMSSIFIfD
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UNCUSSIFIED
391
But I found him. In fact he was an imposter. He
is a fraud, but he is an imposter, and he had studied his
character fairly well. And everything that he had told us
about himself was borne out in written form in the literature
that I found. I took pictures of him with he and my wife,
and then gave the pictures to North so that he wouldn't
suspect that I was giving them to somebody to have him
checked out. And we tried to — I tried to go home at night
and take my notes, and compile summaries that could then be
given to North so that he could check them out.
Q To your knowledge, were any other people at the NSC
knowledgeable of your dealings with al-Masoudi? Of any of
your dealings with al-Masoudi?
A It's possible Fawn may have heard the neune in pass-
ing.
Q Do you recall any involvement of Howard Teicher with
respect to al-Masoudi?
A Yeah, Teicher '3 name came out in the very first
conversation with al-Masoudi and Katke, and the assertion
from Katke was that al-Masoudi had provided the information
that helped the Kuwaitis avoid the bombing attack on Amir.
Anyway, he continually used Teicher 's name.
And when I raised it to North, he told me that in
fact this individual had been very helpful to Teicher, but he
didn't elaborate on it. And when I would provide him what was
ifoi nooin
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CLASSiHED
392
intelligence details provided by al-Masoudi, he often
remarked that that tracked, and that seemed to indicate that
al-Masoudi was ahead of the news cycle, and therefore would
have not known those things if he hadn't been in some way an
active participant or had contacted people who were active
participants .
Q Do you recall some time in June of 1985, when
Teicher lent some assistance in obtaining a visa for al-
Masoudi 's brother?
A Well, al-Masoudi asserted that Teicher did that. I
never bothered to check out whether or not he did.
Q Did you have any conversations with Teicher,
directly, about al-Masoudi?
A I don't believe so.
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assife
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And the only official response I ever got read back to me was
that he had had one meeting at the Central Intelligence
Agency, and their analysis was he was probably who he said he
was, that he was a distaff prince who was a significant
threat to the Saudi regime. But he was probably who he said
he was .
BY MR. KAPLAN:
Q I want to go back to the trip that we just covered
briefly before, in which you and al-Masoudi and a DEA agent,
I believe named^^^^^^^^B travel led to England and then on
to ^^mi^m^^i^^^^B
Did North arrange for^^BHto accompany you?
A Yes.
Q Did you ask North to arrange to have a Federal
agent accompany you? Or did North volunteer^^^^Hto take
this trip?
A I think he volunteered^^^^^nd I think it had
more to do with al-Masoudi 's hostage business than anything
else.
Q Did you know who^^^^|.was at that time?
A I met ^^^^9 s'^d somebody named^^^^^-and I can ' t
remember the guy's last name — and —
Q Was it
A Yes. In North's office
Q When did you meet them?
UNCLASSIFIED
399
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/
A It was prior to the trip. I don't know how much
prior to the trip. But I was asked to recount for them what
al-Masoudi"had told me about the hostages.
Q Did you know at that time, or were you told at that
time that^^^^|and^^^H^|were OEA agents?
A I think I knew at that tine. I don't know whether
I knew right then and there, but by the time he got on the
plane in Atlanta, I knew he was a OEA agent.
Q Did you have an understanding as to the purpose of
.accompanying you on the travel to England and then^H
A I had a very good understanding he was there as a
passive observer.
Q A passive observer of what?
A Of al-Masoudi.
Q What was supposed to be the product of his observa-
tion?
A I don't think much in London, but I think
he was supposed to keep kind of good tabs on him.
Q Who reguested^^^^Hto keep good tabs on al-Masoudi?
A I guess North.
Q what was the purpose of — if you know--of whyj
was keeping tabs on al-Masoudi?
A Well, I think at that point they were treating his
offer on assistance on theS Ji^ait;}i^s|(f|l|.f)}pf^<|y ly.
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CLASSIRED
395
Q When did you first become aware that al-Masoudi was
under investigation by the FBI in connection with a check
that he had bounced at the William Penn Bank?
A Well, if I can dissect your word, investigation.
Q Yes.
A What had happened was, the bank had undergone its
annual FDIC and state auditor review in 19 — it was fairly
early on. I think it was like May-June. And of course this
bad check was on their books, and so the FBI is the inves-
tigatory arm of these FDIC investigations. And they wanted
to know about the check.
My first contact with an FBI agent was when I went
to Philadelphia to meet with the board of directors. They
had the FBI agent there in their offices already, and he was
undergoing a process of investigation at that time.
I thought that matter was somewhat handled and
resolved until it became clear that al-Masoudi was not who he
said he was, and therefore, the check became more likely to
be fraud, but the next real contact on that subject was when
FBI agents contacted Colonel North, myself, and then subse-
quently my brother and his best frieid, and my best friend.
Q Well, why, if you know, did the FBI agents contact
your brother and your mutual best friend?
A We had all — I had borrowed money from my brother
and his best friend, and from my best friend, in order to meet
mnmi
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UNCLASSIFIED
396
what al-Masoudi had described as a registration fee for the
oil contract.
Q Is your brother's name Donald Miller?
A That's correct.
Q Do you recall that Colonel North was first inter-
viewed by FBI agents about al-Masoudi some time in mid-July
of 1985?
A He was contacted initially, I think, and then
subsequently interviewed, but I think there was a lag period
between the two of them, and it took me a long time to get
the FBI agent to call me back.
Q Was he interviewed at a time when you were overseas'
A Must have been because I saw the agent shortly
after I came back.
Q Did the agent try to contact you when you were
overseas?
A I don't recall.
Q Do you recall IBC's having received messages for
you from the agent while you were overseas?
A I don't specifically recall. It's possible.
Q Did you ever ask Colonel H?rth to respond to FBI
calls to you, in an effort for them to set up an interview
with you?
A I'm sorry. Could you say that again.
Q Did you ever ask Colonel North to call an FBI agent
iffort for them to set up
IIIUSSIFIED
402
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who was having difficulty getting in touch with you?
A No. It was the other way around. I asked Colonel
North to get in touch with the FBI agent and ask him to get in
touch with me because the guy wasn't returning my phone calls.
Q Do you recall the name of the FBI agent?
A Kumars ik.
Q At the time that Kumars ik first interviewed you, to
the best of your recollection what was your state of mind as
to the bonafides of al-Masoudi?
A At that point it was a 50/50 proposition. I had the
FBI telling me that he may well be a fraud. They weren't
saying — Kumars ik did not say in the meeting that he was a
fraud. He simply asked the questions that led me to believe
that he felt he was.
And on the other hand, we had the Central Intel-
ligence Agency saying he probably was who he said he was.
And everything that seemed to indicate, in my meetings
overseas with the people who held themselves out as officials
of the Saudi Arabian government, and other major
organizations, seemed to indicate that the guy was who he
said he was. So I thought at best at that point, it was
about a 50/50 proposition.
Q Did Colonel North expres
view as to al-Masoudi 's bonafides?
A I think that shortly thereafter, that he sent
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somebody to Jedda, and his words were that his friend went and
had green tea with the real Jewel, and our guy didn't ever
register, is what he said.
Q Was the person that he sent to Jedda to drink this
green tea Mr. Kopp?
A I believe it was Mr. Kopp, but I've got very little
to go on in that belief.
Q And by Mr. Kopp, at least I am referring to General
Secord.
A Yes.
Q I take it that's your understanding to that as well?
A Yes.
Q Do you recall the date of your first interview with
the FBI agent?
A Not specifically. I wouldn't call it much of an
interview. I wholesale turned over to him all the paperwork
that I had. In fact I gave him some of my originals of the
al-Masoudi materials
Q Did that interview take place in early September
1985?
A That sounds about right. Tt was in my office.
MR. DUDLEY: We're not talking about the meeting in
Philadelphia?
THE WITNESS: No, no. In my office.
BY MR. KAPLAN:
mmwa
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NCLASSra
399
Q I take it — just to clarify the record — that you had
a brief conversation with an FBI agent in Philadelphia some
time, a couple months prior to this at least formal meeting
with the FBI that took place in your office?
A Yes.
Q With Agent Kumars ik from the Washington Field
Office, is that correct?
A Correct. And the Philadelphia agent expressed no
reservation about the guy's identify, so —
Q Okay. Did you have any discussions with Colonel
North, that you recall today, about what kind of information
you would give to the FBI agent, prior to the first interview
in early September 1985?
A I don't recall, specifically, a conversation about
what I would give the agent.
Q Did Colonel North ask you to hold back any informa-
tion from the FBI agent?
A I don't remember him asking me.
Q Did you tell the FBI agent that the CIA had passed
on, at least for the time-being, the bonafides of al-Masoudi?
A I don't recall that, but if it had been done by
that time I probably would have passed that on to him.
Q There would have been no conscious_ decision^ on
your part, not to have held out to the FBI?
A Well, in all honesty, if I was worried about that,
lecision, on
NCIASS!
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I certainly would not have given him all the records I gave
him. I gave him my originals on several documents and I've
never gotten them back, so--
Q My question a moment ago was, did North ask you to
withhold any information from the FBI. I just want to
rephrase it so that we don't get caught up in a semantic
difference.
Did North instruct you to withhold any information
from the FBI in the interview that you had in early September?
A Not that I recall.
Q Did you inform North that this interview was going
to take place?
A Probably.
Q Did you talk with North afterwards about the
substance of the interview?
A Yes.
Q All right. Now from a variety of documentation that
we have, and some of which we discussed a moment ago — that
is, the Treasury reports — you continued to deal with al-
Masoudi for some time after September of 1985, is that
correct?
A Yes.
Q When did you conc^lud^t^ha^ ^l^^Mdaoudi^as in fact an
imposter?
mtm
Well, I knew for sure when whoever it was went to
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drink green tea with him, but I can't tell you —
Q Do you recall when that was?
A I don't recall the precise date of that. What
happened after Kumarsik came to see me the first time, was
that I went to the Library of Congress because I figured that
their records would be more complete than the McKelden
Library, and I tried to find as much as I could about Ibrahim
al-Masoudi, and the genealogical lines that he had implied in
previous conversations.
And again I provided that information to North. I
was very skeptical of him while he was in Geneva, and in fact
I was preparing to send him a final transfer, and ultimately
called Kumarsik and said, look, you know, I'm still sending
this guy money. If you believe him — if you can prove that he
is not who he says he is, then you'd better tell me now
because I'm sending him money.
And Kumarsik said, "I wouldn't send him any more
money if I were you. I don't think he is who he says he is."
Q Do you recall when that was?
A Well, some time in October, I guess.
Q Was this in late October, jarly November, when in
fact you did send him some traveler's checks?
A Probably. But the DEA guys and Kopp continued with
him for a very short period of time after I was ready to be
done with him, and it had to do with the hostages, and this--
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something that was going on at the time, and somehow he was
involved. So there was some activity, even after I knew him
to be an imposter, and he received some money from me, even
after I knew him to be an imposter.
Q Did North encourage you to continue dealing with
r. 1-Masoudi after you, in your own mind, determined that you
thought he was an imposter?
A Actually, he asked me to get out of the middle of
it, and al-Masoudi kept trying to draw me back into it, and
North kept asking me to stay out of it, and I agreed to that.
Q But you did testify that North approved the
traveler's checks that were sent on November 1st and November
6th of 1985?
A Right.
Q Did you ever have any discussions with North, or
conversations with North about delaying the investigation
into al-Masoudi 's bonafides?
A No.
Q Did North ever suggest to you that it would be
best, for any reason, if that investigation were delayed?
A Not that I recall.
Q Did there come a time when you cut off all contact
and communications with al-Masoudi?
A Well, I stopped dealing with him I guess the day he
called me from jail in Geneva.
UNCUISSinED
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Q When was that?
A I think it was some in November. Some time in
November .
Q Do you recall a conversation with Agent Kumarsik
toward the end of October of 1985 in which you told Kumarsik
that you would completely cooperate with the FBI to attempt
to lure al-Masoudi to the United States?
A Yeah. In fact that was the last conversation I was
recounting to you. Basically what I said to him was, that
the only person I knew, that he still thought, to his way of
thinking- -al-Masoudi 's way of thinking — I was the only
individual that he still believed believed in him.
And if I had told him that everything was all
right, come on home, he'd come on home.
Q Nonetheless, you made some payments of some $14,000
to al-Masoudi in Geneva after the agreement that you would
cooperate, and those payments were approved by Colonel North?
A That's correct.
MR. KAPLAN: I'm going to ask the reporter to mark
as Deposition Exhibit 28, a copy of what appears to be a
Telex from you to a Mr. Robert Vidon, and a Mr. Cockrell at
the Credit Suisse Banque, in which you inform them that al-
Masoudi, or anyone purporting to be al-Masoudi, has no
authority to act in any manner as an agent of IBC.
THE WITNESS: Correct.
WM
jwoiRE
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BY HR. KAPLAN!
Q Did IBC have accounts at the Credit Suisse Banque?
A No, no. al-Masoudi had represented to me that
these individuals had set up an account for him, and that he
was going to use the account for his gold and oil transac-
tions, these transactions for the benefit of the resistance.
Q Because he had informed you that this contract was
in the name of International Business Communications, is that
why you wanted to make clear to these individuals that he had
no authority to act on their behalf?
A That's precisely.
MR. KAPLAN: Off the record for a second.
[Brief discussion off the record.]
BY MR. KAPLAN:
Q Have you, Mr. Miller, made a calculation of the
amount of money that you expended on activities that you
undertook with al-Masoudi?
A Yes.
Q How much money was that?
A At the present time, in professional and expense
reimbursements, travel and so forth, it is about $367,000.
mm kQQKKn
[Witness and attorney consult.]
THE WITNESS: The thing that's not calculated in
that figure is expenses by myself personally, and he lived at
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niy house for an entire month, and he's a very expensive
individual . So I have no idea what my personal loss is
associated with it.
BY MR. KAPLAN:
Q Okay. Can you describe, for the record, what sorts
of items this money was used to pay for.
A Traveler's checks for his travel overseas, reimbur-
sement for office expenditures, air-traffic expenses, and in
the case of one item, $104,000 to his attorneys for the
reimbursement of forfeiture of a performance bond.
Q That's the disbursement to Gary Bagdasarian that
you testified about yesterday?
A Correct. And 25,000 in good-faith payment to the
William Penn Bank in Philadelphia.
Q How much of those expenses, if you know, could be
allocated or attributed to al-Hasoudi's hostage-rescue
efforts?
A I've never separated it out that way.
Q Approximately. Would it be half of that?
A I would say that the largest expenditures for al-
Masoudi came at a time when he had already begun to olfer
help, and that probably was a pretty significant factor in
extending him the credit. \\^l \ h\\lf\i
Q Was North kept regularly apprised of your expenses
as well as your activities with al-Masoudi?
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A Yes.
Q Did North approve these expenses?
A He approved the large ones, in specific, and in
general, the smaller.
Q What was the ultimate source of the money expended
or lost on al-Masoudi?
A Well, in terms of the 1099-income that I just
recounted to you, that we have charged him with under a 1099-
Q Charged who with?
A al-Masoudi. Most of that money now has been fully
reimbursed out of the assistance money.
Q That is the centra-assistance money that was paid
to IBC by NEPL?
A By NEPl and other sources .
Q When you say most of that money has been reimbursed,
is that separate from the 10 percent charge, or commission
that you began to take in 1986, and to which you testified
yesterday, and on June 2 3rd?
A That's correct.
Q Who approved, if anyone, the reimbursement from the
NEPL contra-assistance payments, of these monies expended on
behalf of al-Masoudi's activities^ -„, ^„ flrtrtiBTf?"P\
A colonel North. 0 ll ||U"l5dl M lO
Q Was there a specific conversation, or conversations
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with North in which you asked him for reimbursement for these
losses?
A Yes.
Q Did he tell you that you should reimburse yourself
for these losses from the contra-assistance payments that
were being made by NEPL to IBC7
A Yes.
MR. KAPLAN: I have no further questions. Thank
you.
[Whereupon, at 12:15 p.m., the deposition was
adjourned. ]
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UNCUSSIFIED
CERTIFICATE OF NOTARY REPORTER
I, Terry Barham, the officer before whom the
foregoing deposition was taken, do hereby certify that the
witness whose testimony appears in the foregoing transcript
was duly sworn by me; that the testimony of said witness was
taken by me and thereaftrer reduced to typewriting by me or
under my supervision; that said deposition transcript is a
true record of the testimony given by said witness; that I an
neither counsel for, related to, nor employed by any of the
parties to the action in which this deposition was taken;
and, further, that I am not a relative or employee of any
attorney or counsel employed by the parties hereto, nor
financially or otherwise interested in the outcome of the
action.
^ — Terry
and for
My commission expires May 15, 1989.
Birhanij^^Wotary Pu
orj th^TDistrict of
Public in
Columbia
UNWSSIFIED
415
BNWssro
ORCUSSIFIED
SELECT COMMITTEE TO INVESTIGATE COVERT
ARMS TRANSACTIONS WITH IRAN
U.S. HOUSE OF REPRESENTATIVES
AND
SELECT COMMITTEE ON SECRET MILITARY ASSISTANCE
TO IRAN AND THE NICARAGUAN OPPOSITION
UNITED STATES SENATE
Tuesday, September 15, 1987
Washington, D.C.
Deposition of RICHARD RODERICK MILLER taken on
behalf of the Select Committees above cited, pursuant to
notice, commencing at 9:30 a.m. in Room 901 of the Hart
Senate Office Building, before Ronald Meek, a notary public
in and for the District of Columbia, when were present:
For the House Select Committee:
THOMAS FRYMAN, Esq.
SPENCER OLIVER, Esq.
VICTOR ZANGLA, Esq.
For the Senate Select Committee
KEN BUCK, Esq.
Partially Declassified/Released on A?- :£^ - P7
under provisions of E.O. 12356
by N. Menan, National Security Council
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For the deponent:
RONALD G. PRECUP, Esq.
Nussbaum, Owen & Webster
One Thomas Circle
Washington, D. C. 20005
CONTENTS
Examination by counsel for
Paqe
House Select Committee
411
EXHIBITS
Exhibits
Marked
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•'-••
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Whereupon,
RICHARD RODERICK MILLER
was called as a witness and, having previously been duly
sworn, was further examined and further testified as follows:
EXAMINATION BY COUNSEL FOR
THE HOUSE SELECT COMMITTEE
BY MR. FRYMAN:
Q Mr. Miller, this is a continuation of your prior
deposition before the Senate and House Select Committees.
You are still under subpoena, and the immunity orders of the
two Committees which have been marked as exhibits, continue
to be applicable to this session today, and I again remind
you that you are still under oath from your previous sessions.
By this first question, you will know inw^ we are in
this secure room.
Mr. Miller, have you ever been employed by, or have
you ever been a contract agent for any intelligence agency,
including the National Security Agency or the National
Security Council, or any intelligence branch of any depart-
ment or agency?
A No, other than the business relationship which I've
already described to you with Oliver North, and the short
period I worked for the Federal Preparedness Agency at GSA
<N
which was about three months. That doesn't qualify as an
intelligence agayar, j^ft '^ ^qn jmw^^^ the FEMA, Federal
n(!r/«?i?M
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Q Well, your work with Colonel North, did you
consider that work to be work for an intelligence agency?
A No.
Q Did you consider yourself to be a contract agent
for any intelligence agency?
A No.
Q Were you ever present in Colonel North's office
when he placed a telephone call to Bunker Hunt?
A I think I was present in his office when he called
Bunker Hunt. I remember the specifics of his conversation,
but I can't tell you whether I was there, or whether he
repeated it to me.
Q Was it your understanding that at the time Colonel
North had this telephone conversation with Bunker Hunt, that
William Casey was present in Mr. Hunt's office?
A That's correct, although I'm not sure it was the
of£J.ce. I was under the impression it was his house.
Q How did you know this?
A He told me.
Q Colonel North told you?
A Colonel North told me. That's right.
Q What did he tell you about this conversation?
A He told me that he called — he recited, I think,
three of the four items that I asked him to discuss with Mr.
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Hunt, and Mr. Hunt said "I have a friend of yours here," and
Ollie said he said who's that, and he said, "Bill Casey, • and
Ollie said, "Give him my regards." And I don't think he
recounted that he and Casey actually talked.
Q What were the items that you had asked Colonel
North to discuss with Mr. Hunt?
A I have to do it from memory. They're on a piece of
paper that you've already got in your exhibits. But that
there was an ongoing — the basic thrust was that there was an
ongoing supply effort, and that Bunker's money had helped to I
j
produce that, and what was needed was the second half of his !
contribution. j
!
Q Do you recall when this conversation occurred? j
A All I can remember is that he was in his old
office. I don't remember a specific date.
Q When did he leave his old office, as you recall?
A I don't remember, specifically.
- Q Did Colonel North tell you Mr. Hunt's response to
these matters that he had raised with him?
A I don't recall any commitment coming out of the
conversation from Mr. Hunt. I don't remember any commitment
by Mr. Hunt as a result of the conversation, although at a
later, much shorter period of time from then, he did make
good on the second half of his contribution.
Q Did Co^<iq^i^grtJi^^a<V^.%Si.^^ anything that Mr.
iTK(f«i)f(jmitrf
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Hunt had said in this conversation?
A The only thing I can remember is what I've just
told you.
Q With respect to the presence of Mr. Casey?
A Correct. That's not uncharacteristic of Mr. Hunt,
either. He tends to be much more of a listener than a
speaker.
Q Did Colonel North say anything to you with respect
to why Mr: Casey was in Mr. Hunt's office at that time?-
A No.
Q Mr. Miller, do you recall any discussions with
Frank Gomez about what I will describe as the "contra-
assistance network" or the group of bank accounts of IBC, IC,
Inc., and NEPL, and Mr. Gomez's reservations about the use of
these accounts for transferring funds?
A I would say that Frank expressed a reluctance to be
involved in the private funding, initially because it involved
IBC directly, and I think we were agreed that that was
something to be changed. And then, ultimately, I think he
did it for personal commitment reasons to the cause, but
again, I think with some reservation, and I think I prevailed
upon him because I was convinced that — and I think he was con-
vinced--there wasn't anybody else to do it at the time.
Q Was that the argioment you made to him as to why you
should do it?
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A Yes. I
Q Did you make any other arguments? |
I
A Not that I recall. In fact I don't remember that [
one in specific terms, but I'm pretty certain that was the |
I
thrust of my appeal to him.
Q Why did you believe that you and your organizations j
were the only person and entity that could do this? ]
A We were very familiar with the other political
organizations that were involved, and none of them seemed to
be directing raw financial resources to the resistance. A
lot of them were spending money on political activities, but
nobody was giving money, or working to raise money and give
it directly to the resistance. A lot of people claimed they |
were, but it wasn't happening.
So there seemed to be nobody else doing it, and
Colonel North seemed to be in desperate need of somebody to do
it, and those two things led me to conclude that.
- Q As I understand your prior testimony. Colonel North
merely asked you to provide a bank account, or bank accounts,
where monies could be deposited, and from which he could
direct disbursement from the accounts .
Is that, in substance, what he asked you, or the
assistance that he asked you to provide?
A No, I don't think so, because our involvement with
the financial end really started with al-Massoudi, which was
end really started with .
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far more complicated than that, and progressed through
actually going out and raising funds, by virtue of the
conversations with John Ramsey at what seemed to be critical
moments in Colonel North's timetable.
And he was quite clear that we were involved from
the beginning with a fund-raising effort, and I'm sure he
understood that that entailed much more than just setting up
bank accounts .
Q .You recall, do you not, Mr. Miller, and you have
testified about, have you not, a meeting that you attended
with Colonel North and Mr. Channell in July of 1985, where
there was a discussion of how funds would be transferred that
were raised by NEPL?
A Yes.
Q It was at this dinner meeting that Colonel North
told Mr. Channell that the funds should be transferred to the
IBC account, or to one of your accounts?
. A Correct .
Q You understood from Colonel North, that you would
follow his directions about the disbursements of the funds
transferred to you from Mr. Channell, is that correct?
A That's correct.
Q Now, following that conversation, funds transferred
by Mr. Channell to your accounts exceeded several million
dollars, did they not?
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A That's correct.
Q What was the amount of funds that you were respon- !
sible for raising directly for the contras? Was it under 1
$100,000? I
I
A I don't think you can place it in that context
because we were responsible to Mr. Channell for activities and|
work assignments that led to him raising that money. So if
you would like to take all the millions of dollars and take
some percentage of it, I might try and agree with you, but I
can't put a number on that.
Q But the contributions that you asked for yourself
totalled less than $100,000, did they not?
A What do you mean, "asked for myself"?
Q Well, did you ever ask a contributor, or ask anyone
to contribute funds for the purpose of assisting the Nicara-
guan resistance?
A Yeah. I made the direct appeal to John Ramsey on
two occasions. We had the direct appeal to Mrs. Newington on
another occasion. Those were the only times I actually asked
somebody for money. The rest of the times I was present, or
a large number of the rest of the times X was present.
Q So with respect to the responsibility for maintain-
ing an account to receive funds from Mr. Channell, and to
disburse funds from that account pursuant to the direction of
Colonel North, to perform those functions it was not necessary
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to have any relationship with the political figures in the
Nicaraguan resistance, or to have any relationship with
contributors, was it not?
A I'm afraid I don't understand your question. If
your implication is that that activity was somehow discon-
nected from the rest of the activities that we performed for
Mr. Channell, or Colonel North, or the political resistance,
I totally disagree with that.
Q Well, Mr. Miller, whether it was disconnected, or
not, it was not necessary, in order to operate these two
accounts, and receive funds from Mr. Channell and disburse
funds according to the direction of Colonel North, that you
have any relationship with members of the resistance, or that
you have any relationship with Mr. Channel! 's contributors,
was it?
MR. PRECUP: Objection. Mr. Fryman, would you
reformulate that. I think the witness is having trouble with
the word "necessary. " Necessary on what basis? I think
he's explained as a matter of fact what occurred, and has
also testified that that was an important connection on all
ends of those fronts, for him. So it's very difficult for
him to deal with the word "necessary" which may be used in a
vacuum.
MR. FRYMAN: All right. Mr. Precup, what I am
trying to do i|_li»^ follow upon his prior answer, where he
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said that he explained to Mr. Gomez, that if Mr. Miller and
IBC did not perform this function that had been requested by
Colonel North, there was no one else to do it.
What I fail to understand is what was unique about
Mr. Miller's situation, or IBC's situation, and why someone
else could not do that, and that's my ojb^oct^ron in"a^«^line
of questioning.
MR. PRECUP: Well, perhaps the witness could answer
that general inquiry of yours.
THE WITNESS: Well, as I told you previously, I am
very conversant, and we were at the time very conversant with
the other organizations who were capable of raising money and
working with fund-raisers, and working with the resistance
figures, and who had Colonel North's trust, and I didn't feel
there was anybody else out there who had the right elements
to do this .
I didn't see anybody else, and I guess Ollie North
didn't either, because I don't get the feeling he asked many
other people.
BY MR. FRYMAN:
Q Well, I have to then press the question, Mr.
Miller. What difference did it make, whether or not you had
had any relationship with these organizations? Colonel North
was instructing Mr. Channel! to transfer funds to a specific
account, and ¥#V5*ik19 jfc^'Spr prior testimony, he was giving
to_your prior t
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you instructions about specific accounts to which you were to
transfer funds. I
Now what difference does it make as to whether you
had had any prior relationship with anyone in order to
perform those two functions?
A Well, if I gave it 30 minutes of thought I'd come up
with a longer list, but I think the principal elements were
the trust that he had in us. I think they were the trust that
Mr. Channe'll had in us, and I think it was the trust that the
resistance figures and the political entities had in us — were
we to become known as we were, eventually, by some of these
people — that they would not be upset, or they would not be
overly concerned about the involvement that we had. And all
those things turned out to be correct.
And so, I think at the time, it was an intuitive
decision, but I think it was accurate, because, ultimately,
all of them became aware of our responsibility and none of
them seemed to have voiced much distress about it.
Q When did you understand that the resistance
figures, or any of the resistance figures became aware that
the NEPL funds were being transferred into bank accounts
controlled by you, and disbursed by you?
A In terms of having NEPL funds transferred, I would
say not until November or December of this past year.
funds that you were trans-
Q Well,
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f erring, other than NEPL funds?
A Yes.
Q What were those?
A The Heritage Foundation $100,000. S60,000 from a
gentleman by the name of MacAleer, and I have yet to know
who, exactly, that is. And another gentleman by the name of
Barness. But you asked the question in terms of transferring
NEPL funds.
They were aware, long before then, and in different
times, that we were responsible for transferring funds.
Q So you say that you're not aware that any resistance
figure was aware of your role in transferring NEPL funds prior
to November of 1986?
A Well, let me put a finer point on it than that.
They were not aware that they were NEPL funds that were being
transferred to them. I would say with the sole exception of
Adolf o Calero^who had some indication that — well, he had
received checks directly from NEPL, and he had received checks
as_a result of fund-raising activities. But in terms of our
transferring NEPL funds and the funds being known as NEPL
money, he'd be the sole exception until November or December.
Q When do you understand that Mr. Calero first became
aware that you were transferring funds to him from one of
your accounts?
A I had_a jnfiaj:i|g^j4i|^4^f\ the Connecticut Club
■ Jf^i-
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INCUSSinED
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Hotel in late October or November of '86, and in that
meeting, per Colonel North's instructions, I was to get from
him a bank account number, and corporate name to carry out a
transfer, both Colonel North and I knowing that I already
knew it, and this was simply Mr. Calero giving it to me
without knowing that I had been the person transferring it
before.
Q So the first time you believe that Mr. Calero was
aware that one of your accounts was the source of funds'
transferred to him was October or November 1986?
A No. Now you've changed your question. We trans-
ferred from IBC to the NDC, very early on in the process,
money that was a result of NEPL fund-raising, and actually
went — I gave the check to — i think it was Bosco Matamoros,
and I think it was $25,000.
Q Well, what did you understand was the significance
of this conversation you just described in October or November
of -1986?
A It was the first time that Mr. Calero was aware
that we were responsible for transferring money, large sums
of money into his accounts from overseas bank accounts.
Q How much money did you transfer to Mr. Calero after
October or November 19867
A We made, I believe, a $75,000 transfer and an
$80,000 transfer. That's off the top of my head. I don't
ii^i.- That's off the top
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have the documents in front of me.
Q Your explanation to Mr. Gomez as to why your
organization should perform these services was simply that
there was no one else that could do it?
A Well, as I said, I think that was the principal
thrust of my argument to him. I'm sure there were other
elements involved.
Q That's what you recall today?
A Yes .
Q Did you ever discuss the propriety or legality of
your organization being involved in these transfers with Mr.
Gomez?
A I may have reported back to him on my conversations
with the tax attorney at the time of the al-Massoudi business,
and I probably discussed the neutrality ^ct at some point
with him, because that was, again, our principal focus in that
timeframe.
- Q Did you discuss the neutrality act with any
attorney?
A Not in that timeframe, no. Actually, I considered
Frank more expert in that than me, after 20 years of foreign
service.
Q The consultation with the tax attorney that you
referred to did not concern the transfers of Mr. Channell and
the -ii nhiiT-comonhg, j^rffl||-fH^hj|^r;gy^y|^HQr-»h9 xhe specific
iiwwt^^mtrf'
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consultation related to your prior involvement with al-
Massoudi, is that correct?
A I think you're asking me to discuss matters that I
discussed with my attorney at the time. I'm responsible to
answer that?
[Counsel and witness confer.]
THE WITNESS: Okay. The questions with the
attorneys involved not just al-Massoudi, but also the
legality of handling the accounts, and the way they wer^
handled.
BY MR. FRYMAN:
Q Did you have any discussion with attorneys about
transfers through the IBC and the Cayman Islands account,
after your meeting with Colonel North and Mr. Channell in
July of 1985?
A I mean that's all the way up till today.
MR. FRECUP: Yes, it is. We really need an end
date on that, so as not to impinge on the attorney-client
privilege.
THE WITNESS: Is there a specific timeframe that
you're referring to?
MR. FRYMAN: Let's say during the period beginning
July 1985 through November 1986.
THE WITNESS: And would you repeat the question.
(The reporter read back the pending question.]
reporter reaa oacK tne per
TiMni Aooirirf^
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THE WITNESS: Yes.
BY MR. FRYMAN:
When were those discussions?
May of 1986.
And who was the attorney?
Earl Dudley. I think that's right, isn't it? May?
Any other discussions with an attorney during the
time period July 1985 through November 1986?
A ^ot that I can recall.
Q Mr. Miller, in one of your prior days of testimony,
you stated that you were asked to provide money that was used
in an effort to obtain the release of hostages held in
Lebanon.
Who asked you to provide such funds?
A Well, Colonel North indirectly. As I recall, the
money was requested by al-Massoudi while he was in Geneva,
and I confirmed with Colonel North that it was appropriate,
and I undertook the transfers.
Q How much money was involved?
A Well, I can specifically remember one transfer of
about $18,000 was involved. There was another time when
there was about ^J.0, 000 in airline tickets, and the latter
A
portion of al-Massoudi 's stay in Geneva was predominantly
because he was supposedly involved in this . So whatever
money he spent in that period would have been to that end.
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Q What wa3 the approximate date of this request?
A September.
Q Of 19857
A That's correct.
Q The request came directly to you from al-Massoudi?
A As I recall, that's correct.
Q What was explained to you about the purpose for
which these funds were needed?
,fl
A '\15,000 had to do with the effort to secure the
A
release of the hostages, and I don't remember anything
specific about it, and, as I recall, ^3500 was for living
expenses, and I can't right now remember whether it was al-
Massoudi's oif ^^^^^^^^^HIP^ ^9^"^ r °^ ^^^ agent, that was
there.
Q Was the $15,000, to your understanding, to be paid
to the persons holding the hostages?
A I don't believe so. I mean, if that was the case,
it -wasn't said to me.
Q Was there any explanation given to you about what
was to be done with the )^15, 0007
A No.
Just that they needed ^15, 0007
Yes.
i
You said there was a later 10,0007
A"
I believe that's correct, yes.
mmwk
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Q What explanation was given to you about the need
for that money?
A I think it was primarily for air travel involved
with al-Massoudi and some associate of his, and I don't know,
maybe some DEA people.
Q Now were both requests in generally the same time
period, in the fall of 1985, or around September of 1985?
A They were almost all of them in the fall of 1985.
Q .Fall of 1985. Mr. Miller, has your organization
been involved in preparing a study of fund-raising efforts
within the United States for either the Sandinisca govern-
ment, or entities sympathetic to the Sandinista government?
A We prepared a white paper for Mr. Channel 1 on
general activities, including fund-raising, and political
activities by members of the left wing in the United States.
Q When was this prepared?
A I think we transmitted it to him in April.
. Q Of 1987?
A That's correct. And we worked on it for about five
weeks, I think.
Q How long a paper was it?
A It was in inches. The entire report to him was
about eight or nine inches tall, including the appendix, and
- JNCLASSIflEP
Q Did you identify in this white paper a number of
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organizations in the United States that had been involved in
fund-raising?
A Yes.
Q Do you recall the number of organizations?
A No, but there were hundreds of them.
Q Hundreds?
A Hundreds . Yes .
Q Over a thousand?
A It seems to me that there's over a thousand. I'm
not sure that a thousand are in my report, but there are
about a thousand organizations.
Q How did you develop this information?
A Mostly from existing written materials from
computer data bases, and through research, and interviews
with members of the House and Senate staffs.
Q Which House staff members did you interview?
A I'd have to talk to the researcher that handled it,
but they talked to some of the Senate Foreign Relations
stjiff, and I believe they talked to some people on the House
Foreign Affairs Committee staff, but I don't know who.
Q Who was the researcher who handled this?
A Fran Jacobawitz. And also Jeff Keffer of my staff.
Q You were paid to do this by Mr. Channell?
A That's correct.
Q How much did he pay you?
UNCLASSIHED
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A I believe it was 15, or maybe\l2,000. I'd have to
look at the invoice.
Q Did Mr. Channell indicate to you what use he
intended to make of this?
A His concern was that there was a lot of political
attacYtaking place against him by members of Congress who
were ignoring similar activities by people on the left.
Q What use did you understand he was to make of this
report?
A He was supposed to use it to go to contributors and
attempt to raise money for a larger public-affairs effort in
the area of Central America.
Q Did you provide Mr. Channell with a number of copies
of the report?
A As I recall, I provided him three copies.
Q You kept a copy, I take it?
A I believe I did, yes. I'm not sure I kept all the
appendixes, although I'm sure they're interstrewn in the
files. A lot of what we put in there was stuff that we'd
accumulated over the last three or four years — mailings by
other organizations, materials attached in forms, and
debates; things we received by requesting a mail copy of
something.
Q Did you suggest this project to Mr. Channell?
A No. In fact I think it was his suggestion.
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Q Did you ever discuss with Mr. Channell making this
report available to any Members of Congress?
A No. In fact, my counsel was that if it were made
available to Members of Congress, it would be an open
declaration of war between the left and the right, and that
the struggle was already screwed up enough, and it didn't
need to be that politicized, and my recommendation was that
it not be used as a political weapon. That was what I
remember my counsel to him being.
Q Are you suggesting by your answer that there was,
then, a discussion with Mr. Channell about whether or not it
should be made available to Members of Congress?
A Absolutely, and in public. Mr. Channell wanted to
make it a public doctunent, and I did not.
Q Did anyone else participate in this discussion?
A Maybe Dan Kuykendall. I don't know whether Frank
ever participated in them or not. I don't remember whether
he >as ever present.
Q Did you ever receive any information from any
source indicating that Mr. Channell ever made a copy of this
report available to any Member of Congress?
A No.
Q Did you ever receive any information from any
source that Mr. Channell ev«r made this regogt^vaj^laillfi to
any Congressional staff member?
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A No.
Q Mr. Miller, in the prior sessions we have discussed
the consulting arrangement that you firm entered into with
David Fischer and Martin Artiano, and I believe it was agreed
that that arrangement was originally entered into in December
of 1985?
A Correct .
Q Did you consult with Oliver North about retaining
David Fischer or Martin Artiano?
A No. In fact I don't even think they were aware of
it until late in '86.
Q When you say "they were aware of it," who are you
referring to?
A I mean he was not aware of it.
Q It's your understanding that Colonel North was not
aware that you had retained Fischer and Artiano until late
1986?
. A Yes. I don't think he understood that until I told
hia that, and I don't think that was until some time in at
least the middle of '86.
Q Did you discuss with anyone in the White House the
retention of Mr. Fischer and Mr. Artiano?
A I don't recall discussing it with anybody.
Q Do you know if Colonel North had ever met David
Fischer prior to December of 1985?
ONClASSinED
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A I really don't. I've never fiSSW either one of
them say either way.
Q Do you know if Colonel North had met Martin Artiano
prior to December of 1985?
A I'm not sure — no, no.
Q Do you recall a $50,000 payment that was made to
Mr. Artiano in January or February of 1986?
A I recall payments to him, without looking at the
records, if you say there was a $50,000 payment in January,
I'm sure there was.
Q We'll get to the records in a minute, but do you
have an independent recollection of a $50,000 payment in
early 1986?
A I remember making a $50,000 payment to Mr. Artiano.
Q And was there a later $50,000 payment to Mr.
Fischer?
A
- Q
A
Q
There may well have been.
Do you recall that?
Not specifically, but there may have been.
You do specif ically recall a $50,000 payment to Mr.
Artiano early in 1986?
A Well, if you would like to put the records in front
of me, I'll look at them. I don't specifically remember a
$50,000 transfer to Mr. Fischer, but if you say one_Jiappened ,
I'll simply take your word for it
UNCUSSIFIED
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Q , Well, my last question related to the payment to -
Mr. Artiano, which I thought you said, in a prior answer, you
did recall a payment to Mr. Artiano.
A I recall a payment to Mr. Artiano for $50,000.
Q What was the purpose of that payment?
A It was a cash call by Mr. Artiano on our agreed
arrangement and he could have made it for $70,000 if he had
wanted to, but $50,000 was the figure he wanted and needed.
Q "What do you mean by a cash call?
A They had the right, under the contract that we had
with them, to require the payment in whatever tiaachtj-^they
wished and sometimes it was $10,000, sometimes it was
$20,000, sometimes it was larger.
Q Under your understanding of the contract, they
could have called for the full payment under the contract in
January of 19867
A No, I don't think 1 would have allowed that. There
was. a lot of work yet to be done under the contract. I
certainly wouldn't have allowed them to call the whole
contract before they'd finished the work on it.
Q But $50,000 was within range, in your view?
Yes.
Did you understand that to be an advance?
No, I didn't consider it an advance.
What's the difference between a cash call and an
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advance?
A I've never made a distinction between the two. The
only thing I use the word cash call in that they were allowed
to decide the amounts that were to come to them, within
reason, and that's just an informal term on my part, cash
call.
Q Did you make payments to Mr. Fischer in 1987?
A Yes.
Q Do you recall the amounts?
A $70,000 and $35,000, I believe.
Q And do you recall the months that those payments
were made?
A No, I don't recall if off the top of my head.
Q Was it early in 1987? January or February?
A I think it went over a couple of months and that
may be the case but, without looking at the records, I don't
remember the specific dates.
. Q What was the reason that you paid Mr. Fischer
$105,000 in 1987?
A That was the amount that was remaining on our
original agreement and he asked for it and so I paid it to
him.
Q Did you make any payments to Mr. Artiano in 1987?
Yes.
How much?
INCUSSIHED
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A I can't remember off the top of my head but they
were in $10,000 or $5,000 increments.
Q What was the reason for those payments?
A That was additional consultation on the part of —
the $5,000 was additional consultation on the part of Mr.
Artiano for business development.
Q In 1987?
A Yes.
Q 'What subjects did you consult with Mr. Artiano
about in 1987?
A Well, we tried to keep him, generally, aware of the
business opportunities we had and we sought his counsel and
advice and when possible, we tried to involve him in our
decisions to get clients. That was business development.
Q At some point, did you stop using Mr. Artiano 's
services in 1987?
A Yes.
. Q When was that?
A I can't recall specifically what date it was.
Q Why did you stop?
A We just had no more use for it.
Q Did Mr. Fischer perform any services for you in
1987?
Oh, yes.
What did he do?
NOLASSiRED
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A Well, he generally served as a partner in the firm,
provided the same kind of workload that the rest of us did.
Q And was the $105,000 his total compensation from
you in 1987?
A No.
Q What else did you pay him?
A Again, off the top of my head, without the records
in front of me, I can't remember a specific number but we
made several payments or received, from him, payments which
represented a net sum from the client. In other words, a i
client would pay his corporation and his corporation would
then transfer IBC's share to IBC. J
Q But the $105,000 was compensation to Mr. Fischer and|
in return for that compensation, he has been providing
services for you during 1987?
MR. PRECUP: Excuse me. I don't believe that was
the witness's prior testimony.
THE WITNESS: No.
MR. PRECUP: He did characterize that $105,000
payment, but not as compensation for current services.
THE WITNESS: That was the remaining amount —
$105,000 was the remaining amount due to Mr. Fischer for our
original contract on the NEPL ac^ivities^
BY MR. FRYMAN
Q And this was the agreement that you reached in
I
lEPL activities.
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December of 1985? !
I
I
A Correct. |
I
Q And what period of time was that agreement to cover?!
A It was for six months and it was agreed that it was |
representative of 24 months of $20,000 a month.
Q So the agreement was for 24 months?
A That's correct. Two years.
Q And that would continue until December of 19877
A That's correct, but they had the right to make cash
calls along the way, within reason.
Q But you had the right to call on Mr. Fischer's
seri^ices until December of 1987 for the $280,000 you were
going to pay him--or the $480,000, correct?
A No. By 1987, we were involved in other efforts
already. As I said, the $105,000 was paid for past activities
for NEPL and the compensation that you are asking me about
now in 1987 was for other business unassociated with NEPL.
. Q Well, Mr. Miller, as I understand your testimony,
you reached an agreement with Mr. Fischer that he was to
provide services for 24 months, is that correct?
A No. The financial commitment from us was for 2 4
months worth of $20,000 a month.
Q And that's unrelated to his doing any work for 24
months?
A No. Ms.i^bacaeL acd^LBCji^aulred a large workload
iiKrf«nit«t»Ktrm
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UNCUSSIFIED
438
by Mr. Artiano and Mr. Fischer in the first seven months, but
initially, that first six months of 1986 there was a tremen-
dous workload and the commitment that we were required to
make to Mr. Artiano and Mr. Fischer, was for two years at
$2 0,000 a month.
Q So, am I correct in understanding your testimony
that you are saying that in effect, Mr. Fischer had completed
his 24 months of work by January of 1987?
A ,Yes. You keep interjecting the word work, when I'm
talking about compensation.
Q Are the two unrelated in your mind?
A The two are unrelated in terms of my financial
commitment to Mr. Fischer, which is what you're asking me
about .
Q So you made a financial commitment to him that was
unrelated to his performing any services for you, is that
what you're saying?
A No.
MR. PRECUP: Mr. Fryman, that isn't what he said.
Don't misfcharacterize his testimony.
MR. FRYMAN: Well, I'm trying to understand his
testimony, Mr. Precup, and I'm finding it somewhat difficult
to understand it.
BY MR. FRYMAM:
Q Now, I'ji Just tJ^Yinfl to^_g®t clear. As I understand |
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it, you reached an agreement with Mr. Fischer in December of
1985, to cover a period of 24 months.
A A financial commitment to Mr. Fischer and Mr.
Artiano for $20,000 a month for 24 months. That's correct.
Q Or a total of $480,000?
A That's correct.
Q Now, were they to provide services for that amount
of money?
A Yes and they did.
Q Were those services to cover any particular period
of time?
A About six months worth of intense activity, yes.
Q So they were to be paid $480,000 for six months of
work, is that what you're saying?
A That's correct.
Q And that six months' work had been completed by
January of 19877
A That's correct.
Q And when you paid him $105,000, you in effect, were
paying him for services that he had already rendered?
A That's correct.
Q Okay. So Mr. Fischer and Mr. Artiano were, in
effect, being compensated a total of $480,000 for six months
work, or $80,000 a month?
A I don't accept it. What was required of me.
t accept it. What was r«
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because we were monopolizing., particularly, Mr. Fischer's
time for that seven months, but predominantly six months in
early 1986, was a commitment to them for 24 months, $20,000 a
month. It was not financially possible to make that commit-
ment without passing it along to the client that required the
work.
Q Mr. Miller, as I understand what you have said, you
made a commitment to pay Mr. Fischer and Mr. Artiano $480,000.
A That's correct.
Q And you understood that they had performed the
services, under that agreement, within a period of six months?
A Yes.
Q And you owed them $480,000 for six months' work?
A That's correct.
Q And according to my arithmetic, that works out to
$80,000 a month.
A Well, that's your arithmetic.
Q Do you disagree with the arithmetic?
A I've already told ycu I disagree with it. What I
made to them was a commitment for $20,000 a month for 24
months . And that was the substance of the commitment to
them. Now, you can divide it up any way you want, but that
was my commitment to them.
Q Just to make sure you and I are on the same wave
length about the elements in the equation, the total amount
elements in the equation
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of funds is $480,000?
A Correct.
Q And the total months of service was six months?
A That's correct also.
Q And in addition to the $480,000 commitment, you had
a separate arrangement with Mr. Artiano for him to provide
additional services directly for IBC, I believe you testified.
A Correct.
Q , And you had separate financial arrangements with
Mr. Fischer, with regard to additional services.
A That's correct also.
Q Off the record.
[Brief pause off the record.]
MR. FRYMAN: All right, we will start with Exhibit
29 and see what happens. It appears from the prior transcript
of Mr. Miller's deposition, that the last exhibit marked was
Number 28. I would ask the reporter then to mark, as Miller
Deposition Exhibit 29 for identification, a report that has
b««n prepared by accountants for the House and Senate
Committees, which summarizes financial data and bank records
of International Business Communications, INTEL Corporation,
Gomez International, Miller Communications, and World Affairs
Counselors, Inc. This report is dated September 14, 1987 and
contains 35 pages
f ' ' ^ '•■*
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I 35 pages.
ililASSinEI^
he documents referred to were
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marked for identification as
Miller Deposition Exhibit No.
29. )
BY MR. FRYMAN:
Q Mr. Miller, I show you Exhibit 29 for identifica-
tion. You will notice that the first sheet is headed
Analysis 3-A, which is a summary sheet of the statement of
cash receipts and disbursements for the period January 1985
to Decembet 1986. The next sheet is a similar summary sheet
which is headed Analysis 3-C, which is an analysis of
disbursements to other organizations for the same period.
There is no sheet headed Analysis 3-B, you will note. The
third sheet is headed Analysis 3-D and is an analysis of
receipts for the IBC-af filiated companies for the same period.
Then following that there are further sheets, three
summary sheets relating to the IBC account, one summary sheet
relating to the IC account, one summary sheet relating to
Midler Communications, and one summary sheet relating to
Gomez International. Following those summary sheets are then
a number of detailed sheets listing the components of the
various accounts that are summarized on the prior sheets.
Now, let's go off the record for a second.
[Brief pause off the_reco^rd^ ]
5 " "
illiiSSflE
BY MR. FRYMAN:
Q Mr. Miller, if you would first turn in Exhibit 29
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to page 10, you will notice, on that page, toward the bottom,
the report indicates that there were payments to IBC of
$22,500 from an entity called ESOP Associates. Are you
familiar with ESOP Associates?
MR. PRECUP: Before the witness answers, Mr.
Fryman, I want to say for the record that we object to the
use of this exhibit for questioning the witness on a wide
number of bases. The document appears, in its 35 pages here,
to be other than complete in that, for example, it has •
analyses 3-A, C and D, but no 3-B, not to mention 1 and 2,
whatever they might be. It is impossible, on a brief
examination, to deteonnine whether this is a correct and
complete analysis, let alone an accurate one of the accounts
it purports to review.
It contains characterizations throughout of payee's
sources of funds and the like. He, of course, assume that
the math is correct, but that's an assumption because we have
not. had a chance to check it ourselves. We don't know what
records in total were used to produce this nor what biases
existed in the persons who did produce it and who are not
here for us to question.
Hence, we do not — the witness does not adopt any
part of this exhibit as a true description of any kind of
reality. With all that said, should anything you care to
point out to him in this document refreshes recollection
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pendently, about a transaction or an event, I, of course,
have no objection to the witness answering that question.
MR. FRYMAN: Mr. Precup, as I indicated when I
marked the document as an exhibit, I'm not asking Mr. Miller
to adopt this analysis as being in its entirety correct. I'm
merely marking it as an exhibit. I'm representing that it is
the analysis prepared by our accountants and I intend to use
it as a basis for putting specific questions to Mr. Miller.
BY MR. FRYMAN;
Q The pending question, Mr. Miller, is derived from
page 10, but I can really ask you the question independently
of page 10. Are you aware that IBC received funds from an
entity called ESOP Associates?
A Yes.
Q What is that entity?
A It's actually called the ESOP Association and it's
the employee stock ownership program association in Washing-
toa«
Q And were they a client of IBC?
A Yes.
Q Do you recall if, in 1985, they paid fees to your
organization in the range of $22,500?
A We were paid $22,500 for the execution of a general
public -affairs program. Some of that was fees; some of that
was program expenditures. As I recall, we refunded about
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$12,SO0 to them. I think that's correct.. I can't remember
the figures specifically.
Q If you would look at page 18, Mr. Miller, you will
notice that there is reflected there a payment by IBC to ESOP
Associates of $13,690. Is that amount consistent with your
recollection of the amount that was paid back to that client?
A We only made one payment to ESOP so that would have
to be it if that's an accurate reflection of my business
records. '
Q Was the payment that you made back to them approxi-
mately in November of 1985, according to your recollection?
A Yes.
Q Am I correct in understanding that the fees that
you received from this client had nothing to do with your
work in connection with the Nicaraguan Resistance?
A That's correct.
Q If you would look again at page 10, there's a
reference to Calero traveler's checks and there's a number of
entries indicating that in April of 1985, you received
$35,000 from Mr. Calero. Is that consistent with your
recollection that you received that amount of money from Mr.
Calero in April of 1985?
MR. PRECUP: Excuse me, Mr. Fryman. You said
$35,000. Perhaps you misspoke^ Our_sheet shows a different
figure .
s you misspoke. Our sheet
ONCUSSIFIEff
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MR. FRYMAN^ In April of 1985, I believe it's
$35,000, Mr. Precup.
MR. PRECUP: You're selecting just the April
figures from that?
MR. FRYMAN: That's right. There's a $4,000 figure
in February of 1985.
MR. PRECUP: All right, we see. Thank you.
THE WITNESS: I recall receiving traveler's checks
from Mr. Galero. Without looking at my business records, I
can't attest to whether your dates are correct or the amounts
are correct, but I was paid by Mr. Calero in traveler's
cheeks .
J'^ MR. FRYMAN:
Q Was it a series of payments in traveler's checks in
April of 1985?
A Well, there was a — yes, for different things and
there were several payments in April of 1985 .
Q Is it your recollection that those payments were in
the range of $35,000?
A I don't have a specific recollection of the range,
but I do recall a $20,000 wire transfer and $10,000 in
traveler's checks specifically.
Q What did you do with the traveler's checks?
A I think most of them were deposited into the
general IBC account and I think some of them I took directly
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and I've forgotten the exact amount.
0 Took directly where?
A I used them for my own personal income. It was a
sole proprietorship in 1985.
Q All right. If you turn to page 11, Mr. Miller, the
exhibit indicates that IBC received approximately $14,000 in
1985 from the Gulf and Caribbean Foundation. Do you recall
your company receiving payments from the Gulf and Caribbean
Foundation?
A Yes.
Q Did your company perform services for the Gulf and
Caribbean Foundation?
A Yes.
Q What was the nature of the services?
A We were their media-^relations and foreign,.policy
advises for their scholars program and their other public
education efforts.
. Q Did you understand that Dan Kuykendall supervised
the operations of the Gulf and Caribbean Foundation?
A Yes.
Q Did you ever discuss the Gulf and Caribbean
Foundation with Oliver North?
A I'm sure I did at one point or another.
Q Do you recall any discussion?
A {{jli ^^tfV^afSf^S^^^'&^^E*^^^^^"' ^ ^° recall that, I
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think the first time that Colonel. North asked me for money,
the money that was eventually transferred to Mr. Robelo's
account — I actually think Colonel North thought I was going
to go to the Gulf and Caribbean sponsors, as opposed to Mr.
Channel, but that's only a sum total recollection. It's not
a specific recollection.
Q You are familiar, of course, with the chart
prepared by Colonel North that was printed in the Tower
Commissioo report and has been marked earlier as an exhibit
in this deposition.
A I was provided a copy of it by your Committee and
I've had a chance to review it.
Q You've seen it before?
A Yes.
Q And you're aware that there's a box on that chart
that indicates the GNC Foundation?
A Yes.
Q Do you have any information as to why Colonel North
included what appears to be a reference to the Gulf and
Caribbean Foundation on that chart?
A No.
Q Do you believe that any discussion you had with
Colonel North could have been the basis for his including
that reference on the chart?
A It's entirely possible but I don't have any
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OhCLASSIRED
449
specific recollections of a conversation either about the
chart or including them in some formal structure.
Q Also on page 11, Mr. Miller, there's an indication
that IBC received $9,800 from Kate Macinnis. Now, was Kate
Macinnis a secretary at your organization?
A No. Kate Macinnis is our office manager.
Q She was an office manager. Is it your recollection
that there was a financial entry in your books showing
receipt of $9,800 from Kate Macinnis?
A No.
Q Do you have any explanation for such an entry?
A Without going back to my books and specific detail,
no. I think it's an error in your document.
Q Mr. Miller. Turn to page 32. On that page, the
report indicates payments by Miller Communications to Kate
Macinnis in February through May of 1986 totaling $35,863.
Do you recall such transfers from Miller Communications to
Kate Macinnis?
A No. Again, I think it is an error in your report.
There is simply the name on the check. I think they are
probably either my draw or travel advance, and she simply
cashed the check.
Q There is a particular entry dated March 24, 1986 for
$31,663, and there is a notation NBW. Do you recall a
transfer to her in that approximdtfi -Smount in March of 1986?
ar in that approximate amc
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A. No. Again, it wasn't. a transfer to her. That is
simply her cashing a check in order to write either a
cashier's check or a treasurer's check to myself.
Q You believe it was one of the two.
A Yes.
Q Do you recall —
A It may have been Kenneth, but I don't ever remember
carrying $31,000 in cash away from the office, so I suspect
it was probably a treasurer's or a cashier's check.
Q Do you recall placing an order for a cashier's
check or a treasurer's check in the amount of $31,663 in
March of 1986?
A Not specifically, but I can check my records. I
don't specifically recall it.
Q If you turn to page 17, Mr. Miller, on that page
you will note that the report indicates that there were IBC
checks to Cash in March of 1986: a check, March 21, for
$2(1,005; a check, March 26, of $20,005, and a check in April,
April 15, for $20,010. Do you recall IBC making such cash
withdrawals in March and April of 1986?
A Not specifically, but I am also not accepting your
assertion that these are cash withdrawals . These may have
n
been interf account transfers or the purchase of treasurer's
checks or cashier's checks..
Q All jrj.<yhtj ."^.yg^^'^gStfJ-iLflPy purchase of treasurer's
»llW[rtl:li'
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checks or cashier's checks in those amounts in March- and
April of 1986?
A None in specific, no.
Q Now, in response to my question about Kate Macinnis
and about these transactions, you have referred, on both
occasions, to the possibility of treasurer's or cashier's
checks in amounts of $20,000 or $30,000. Do you recall that
you obtained cashier's checks or traveler's checks in that
approximate amount at that time?
A I never said traveler's checks. I said treasurer's
checks .
Q I'm sorry, treasurer's checks or cashier's checks.
A Again, I don't in specific detail, but that's
entirely possible that it either was that or these were
inter+account transfers.
Q Well, you say that's entirely possible. Do you
recall making transfers in the range of $20,000-$30,000 by
cashier's checks and treasurer's checks?
A I recall transfers in the amount of $20,000. How
the specific transactions were handled, I can't remember
specifically without looking at my records.
Q So you have no recollection of withdrawals in the
March and April 1986 period that total approximately $100,000
in four transactions, three transactions reflected on page 17
for $20,000 each payable to Cash and the other transaction
each payable to Cash and t
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from Miller Conununications of $30,000 on March 24, payable to
Kate Macinnis?
Q Well, in keeping with what my counsel said earlier
and to reflect my answer a moment ago, I remember $20,000
transfers. I can't, from your document — I do not have, from
your document, a specific refreshment of my recollection
about these individual transfers.
Q What $20,000 transfers do you recall?
A No, I simply remember making $20,000 transfers'.
Q To whom?
A I don't remember specifically whom and I couldn't
remember them off the top of my head without looking at my
business records. Again, they may have been inter-company
transfers.
Q If you were seeking a treasurer's check or a
cashier's check from the bank, would you make the IBC check
payable to Cash?
.A It's been done that way, yes.
Q Might you also make it payable to Kate Macinnis?
A I might make it payable to Kate Macinnis . I might
make it payable to the National Bank of Washington.
Q It would be one of the three?
A Right. It could also be made out to me as an
individual and I could endorse it and the bank would accept
the endorsement . J^ fro^lfii, f4^f(f^4~knie out as a corporation
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with the -bank accepting the endorsement of the corporation.
Q If you would turn to page 13, the exhibit indicates
transfers to IBC totalling $15,000 from the Institute for
North South Issues. Do you recall IBC receiving payments
from the Institute for North South Issues?
A Yes.
Q What was the purpose of those payments?
A We were paid a monthly rent for the office space,
use of the telephones, and other facilities, xeroxing,
receptionist by the Institute of $15,000 a month. I think if
you look at —
Q You said $15,000 a month.
A $1,500 a month, I'm sorry. $1,500 a month.
Q Is it your recollection that you received total
payments of approximately $15,000 for such rent and overhead?
A Well, I specifically remember getting $1,500 a
month from them. These figures are all in $1,500 increments,
so _I would assume these are all rent payments. I don't
believe we've ever received anything but rent payments from
them.
Q You don't recall ever receiving a fee of any sort
from the Institute for North South Issues?
A No.
Q Okay. Also on that page, there's an indication of
a transfer of funds from Ransom F. Shoup and the company,
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payments totalling $15,170. Is that a client of your firm? I
A Yes . j
Q Has your firm performed public'relations services |
for that client?
A Yes.
Q Are those payments unrelated to your work in
connection with the Nicaraguan Resistance?
A Yes.
Q ' Turning to page 14, Mr. Miller, there's an account
that begins on the preceding page, 13, where our accountants
have not been able to identify the source of funds to IBC and
I want to ask you about certain entries on there and just ask
you if you recall what the source of the funds were. In
particular, there's a reference to a payment on September 25,
1985 of $16,340. Do you recall receiving a payment in
approximately that amount at that time?
A Yes.
Q What was the source of those funds?
A I believe, again from just trying to recollect from
your document refreshing my memory that that was a payment by
the Indonesian World Trade Center.
Q Did any such payment have any connection with your
work for the Nicaraguan Resistance?!
A No. i?nl?Lnuu
Q Also on that page, Mr. Miller, there's an entry for
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a payment on March 3/ 1986 of $7,000. Do you recall a
payment in that amount at that time?
A Not specifically.
Q You will also note a payment on June 11, 1986 of
$25,000. Do you recall a $25,000 payment in June of 1986?
A Not specifically.
Q When you say not specifically —
A I have no recollection of that without going back
to my business records.
Q Further down, there's an entry for a payment of
$10,000 on September 29, 1986. Do you recall a payment of
that amount at that time?
A No, I don't recall it.
Q There's an entry for a payment of $8,500 on October
2, 1986. Do you recall a payment of that amount at that time?
A NO.
Q There is an entry for a payment of $38,100 on
November 10, 1986. Do you recall a payment of that amount at
approximately that time?
A I think it's $30,100, but I don't recall the
specifics of that.
Off the record.
(Brief pause off the
BY MR. FRYMAN:
SUSSIFIED
In any case, Mr. Miller, just so there's no
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confusion over this, page 14 indicates a payment of $38,100 I
i
on November 10, 1986. Do you have any recollection of a !
payment in that approximate amount at that approximate time? I
A No. !
MR. PRECUP: Mr. Fryman, I would observe too that |
the word payment is not indicated anywhere on the face of |
this column. It shows a receipt, but whether that's a j
payment or some other transaction is not specified on this
sheet, so if there's some other information that you h^ve
that indicates it's a payment, I would appreciate you telling
the witness that.
MR. FRYMAN: Well, I'm trying to be as nonj^echnical
as possible, Mr. Precup. What the sheet indicates is that
IBC received funds in that amount at approximately that date
and by payment, I meant a payment to IBC.
BY MR. FRYMAN:
Q Finally on this page, Mr. Miller, there's an entry
of .a receipt of $20,000 on November 12, 1986. Do you have
any recollection of the receipt of approximately that amount
at that time?
A I think in that period — no, I don't. I'm sorry. I
don't have a specific recollection. I
Q Further on that page, there are entries indicating j
payments to IBC, or receipts by IBC, of $356,471.66 from the j
U.S. Treasury. Do vpu recall receiving such monies from the 1
lurv. Do you recall recei
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U.S. Treasury?
Oi^CUSSinED
A Yea.
Q What were those funds for?
A These are in relation to the State Department
contracts .
Q There's one there for $14.50 on October 24, 1985.
Do you have any recollection as to what that relates to?
A I don't have a specific recollection, but it may
well be a refund on one of our corporate tax returns.
Q But I take it, you don't believe that relates to
the State Department contract?
A No, I don't think we ever got a check that small
from the State Department.
Q But are the other entries in that column consistent
with your recollection of payments to IBC from the State
Department?
A All but the first one and I would have to verify
that from my business records. The others all seem consis-
tent.
Q Tou recall a series of payments for $12,858?
A That's correct.
Q And you recall a large payment for $216,381.16?
A Yes.
Q And a final payment of $25,670?
A Correct .
ONOUSSIRED
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Q Turning to page 15, there's a notation that your
account received $6,761.55 in December of 1986 from the
Western Goals Foundation. Do you recall receiving a payment
of approximately that amount at that time?
A Yes.
Q What was that for?
A It was for the beginning of a radio program they
wanted to put on the air.
Q And Western Goals was an organization controlled by
Mr. Channel at that time?
A Well, he was involved with it at that time.
Whether he was in direct control, I don't know.
Q Did you consider Mr. Channel the individual who
made the decision to make a payment to you on behalf of
Western Goals?
A In conjunction with Mr. Conrad who was, at that
time, I believe the Executive Director of Western Goals.
_ Q There are also on that page^ entries indicating
receipts of $20,000 from William Mulvey, Inc. Is William
Mulvey, Inc. a client of your firm?
A Yes.
And you've rendered public^relations services for
^
that client?
A And other services as well J
Q And am I correct that the receipts from that client
D
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had nothing to do with your work for the Nicaraguan Resis-
tance?
A That's correct.
Q On that page, there are further series of payments
at this point, beginning after the first two entries, which
are reflected as a debit column, of payments to 1607 Asso-
ciates and 1912 Sunderland Associates. Is it your recollec-
tion that you made such payments to such entities as rent
payments? ,
A Rent and other services .
Q On page 16, Mr. Miller, there are also a series of
payments reflected to Bragg Communications for the period
June 1985 through January of 1986. Is it your recollection
that you made such payments to Bragg Communications for rent
also?
A That's correct.
Q Continuing on page 16, there is an indication of a
payment of $10,000 in November 1986 to Frederick Arguello
from the IBC account. Do you recall making such a payment
from that account in November of 1986?
A It was money that was transferred to him at the
direction of Colonel North.
Q Did this reflect A'£<ls-fc<Jia| ^AfSfifiifl4 *^°'" ^'
Channel , organization? 0 ^J^l AScIFIlD
A Yes. I'm not sure you have the right account, but
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NCLASSIHED
460
Q Our analysis indicates this came out of an IBC bank
account. Is that inconsistent with your recollection?
A My recollection was that it came out of the Miller
Communications account, but that may — I wouldn't be able to
swear to either one of them without looking at the bank
records .
Q In any case, you recall a payment to Frederick
Arguello in November of 1986 of $10,000 that was made at the
direction of Colonel North, right?
A Correct. Can we take a quick break?
Q Sure .
Q Turning to page 16, or continuing on page 16, Mr.
Miller, there are two payments on that page, in July of 1985,
of $50,000 each, to Gary Bagdasarian, and I believe Mr. Kaplan
asked you some questions about Gary Bagdasarian at an earlier
session of your deposition.
But I want to just pursue this a bit more. Do you
recall making two $50,000 payments to Mr. Bagdasarian in July
of 19857
A Yes.
Q I believe you've testified earlier, that this had
some relation to your association with, aldda&aoutii?
A That's correct.
Q Did al-Massoudi request that you make these
sciation with al-Ma&anudi7
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illiSSlFlED
461
payments to Mr. Bagdasarian?
A Yes.
Q What did you understand was the reason for the
payments?
A It was some performance bond which needed to be
satisfied, and Mr. Bagdasarian is his attorney and he was
responsible for taking care of it.
Q Now the association with al-Massoudi was an
association that you were pursuing at the request of Colonel
North, is that correct?
A Correct.
Q Now, did Colonel North arrange for you to be reim-
bursed for this $100,000?
A Yes .
Q How did he do that?
A It was a reimbursement that came, I think before
the end of 1985.
. Q How was the reimbursement paid to you?
A Well, I kept a running ledger sheet which I
provided him copies of, which showed subtractions from the
money given to us by NEPL and other sources, and the subtrac-
tions were for expenditures made by his direction, or on his
behalf, and I would have reported it in that fashion. So it
would have been a subtraction situation for me. I would have
subtracted it from the total .
mjmm
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SIUSSIRED
462
Q So, when you refer to the monies paid by NEPL, are
you referring to the monies paid by NEPL to the IBC account,
that you then relayed to the IC account, and then relayed to
other entities at Colonel North's direction?
A No. As I've testified earlier, the problem that we
encountered was, in the beginning we were doing a lot of
Colonel North's business out of the IBC accounts, and we
eventually tried to move it all into the IC, Inc. account.
Q Right.
A But this is an early instance in which we expended
money directly out of the IBC accounts for one of the things
that he had directed.
Q Right. But going back to your July 1985 meeting
with Colonel North and Mr. Channell, where there was a
discussion that NEPL would transfer a certain number of
dollars to one of your accounts, and then you would arrange
to transfer those monies to other entities at the direction
of .Colonel North — am I correct in understanding from your
answer, that at some point in 1985, Colonel North authorized
you to hold for your own purposes $100,000 of such funds that
NEPL had transferred as reimbursement for these expenditures
to Mr. Bagdasarian?
A Yes. i;;?«^i]>
7JL,
Q Turning to page 17, there's an indication of a
payment by IBC to Bruce Cameron of $10,000 in January 1986.
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463
Do yau- recall paying such an amount to Mr. Cameron? -
A Yes.
Q What was that for?
A It was for a legislative analysis by Mr. Cameron on
the climate on Capitol Hill for continued aid to the Nicara-
guan resistance.
Q Was this for a particular paper that he was
preparing for you, or was it for continued services over a
period of 'time?
A I recall that there was some form of a report —
there may have been more than one — but beyond that, I can't
recall the specifics of the relationship without going back
and looking at my records .
Q How did you happen to retain Mr. Cameron?
A Bruce was recommended to us by PeivKemble of the
Institute for Religion and Democracy, and we received a
recommendation from Elliott Abrams also.
. Q When you say you received a recommendation, do you
recall what they said about him, what was the nature of the
recommendation?
A That he was working hard for the policies, and that
he had been made to pay a heavy price by his former col-
leagues , and that if there was a way to incorporate him into
the effort we should do it. And all those conversations were
predicated on the fact that we vn
mrj^'RWf!^
wg for somebody to
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iii
do precisely that, and in our book those two things were
qualification enough for him.
Q Did Mr. Abrams indicate that Mr. Cameron had been
useful in the effort?
A I don't recall that. I recall Elliott saying that
he was a good man, and that he knew Central America extremely
well and knew the legislative process involving Central
America extremely well.
Q .When did this discussion with Mr. Abrams occur?
A I can't recall, specifically, but some time around
December, I guess.
Q Was it just you and Mr. Abrams?
A As I recall it was a phone conversation, but my
recollection is sketchy. I think I got a letter from Pery
Kemble, and I think I got a phone call from Elliott Abrams.
Q Asking you to retain Cameron?
A Hell, the letter from Pen/Kemble asked me to retain
CaiQieron. The phone call from Elliott Abrams was what I had
just recounted to you.
Q I mean, did you consider that a request by Mr.
Abrams, that you retain Cameron?
A No. I considered it a recommendation by Mr. Abrams.
Q But is it your recollection that that was the
principal subject of the phone call, that he called you with
respect to a recommendation of Mr. Cameron
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A Yes.
Q Are you aware that Mr. Channell also retained Mr.
Cameron in 1986?
A Yes.
Q Do you know the purpose for which Mr. Channell
retained Mr. Cameron?
A Well, in general terms, yes.
Q Did you discuss with Mr. Channell his retention of
Mr. Cameron?
A Well, actually, I think this transaction that you
and I just discussed a moment ago was the beginning of that
relationship, and then I think it continued on. I can't
attest to the financial transactions between the two of them
because I wasn't made aware of them, but the general work
continued to be about the same, legislative analysis.
Q Was Mr. Cameron performing lobbying services?
A I don't think under his contract with NEFL he was
pecformlng lobbying services . He may have received money from
Mr. Channell for lobbying services, but I'm not positive
about that.
Q Was he performing lobbying services for you?
A I didn't consider this lobbying services.
Q What period of time did his services cover for you,
for which you paid him $10,0007 H ||ljL/\NN|r jl' jj
A Actually, I think that isiJlO,000 out of a total
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conunitment to him of about $40,000, and it spanned several
months, and, again, without looking at the letters, the
exchange of letters or subsequent documents in the file, I
can't tell you exactly how many months it was.
But it's at least four months, and it entailed more
than just Mr. Cameron. It entailed employees of Mr. Cameron.
Q Well, is it your recollection that your company
paid him $40,000?
A .No. It's my recollection that the original request
from him was for $40,000, and I think this $10,000 is the
initial payment of that $40,000.
Q Is it your recollection that subsequent payments
came directly from Mr. Channell?
A I think that's right. I'm hazy on my recollection
but I think that's correct.
Q Has there some reason that there was a transfer of
compensation to Mr. Cameron from your organization to Mr.
Channell 's organization?
A Mr. Channell wanted it that way.
Q He did?
A Tes.
Q That's something you recall discussing with Mr.
Channell?
A Yes,
UNOIASSIFIEB
Do you know why he wanted it that way?
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467
He didn't indicate why he wanted it that way?
Not that I specifically remember.
Continuing on page 17 of Exhibit 29, Mr. Miller,
there's a reference to a payment of $9,300 to Ricardo
Carrasco in October of 1985. Do you recall such a payment?
A I don't. I've never seen the name Ricardo Carrasco,
or don't recall seeing it.
Q So you have no idea what such a payment would have
been for?
A Again, I've never heard of Ricardo Carrasco, or at
least I don't remember Ricardo Carrasco in any way.
Q All right. At the bottom of that page, there's an
indication of a payment in September of 1985 to Arturo Cruz
of $10,005. Do you recall such a payment in September of
1985?
A Yes. The five dollars is simply a charge for a
cas_hier's check.
Q So the payment was for $10,0007
A That's correct.
Q We were talking earlier, on that same page, about
the notations of payments to cash in March and April of 1986
for $20,005 and $20,010. Do those amounts indicate to you
that those were cashier^s^ cbf aJra^or treasurer's checks as
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UNGlASSinED
468
A It's entirely possible that those are service
charges for cashier's or treasurer's checks.
Q why did you pay Mr. Cruz $10,000 in September of
1985?
A Colonel North asked me to.
Q What was the source of those funds?
A That was NEPL money.
Q Turning to page 18, we were talking earlier about
payments t)o David Fischer, and you will note that there is an
indication of a $50,000 payment to David Fischer and As-
sociates on April 18, 1986.
Does that refresh your recollection about such a
payment in that amount, in April of 1986?
A Again, Z recall making a $50,000 payment to Mr.
Fischer. I don't recall a specific date, but I'll accept
your record of it.
Q Why did you make a $50,000 payment to Hr. Fischer?
A He requested it.
Q That's the only reason?
A That's correct.
Q You indicated earlier this morning that you had a
commitment to Mr. Fischer and Mr. Artiano to pay them
$480,000, is that correct?,
A That's correct.
Q You understood that they had performed the services
ana ru. • A£«.xaiiw bw paj ^'
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for which they were entitled to be paid that amount during a
period of six months?
A That's correct.
Q That six months began in December of 1985?
A Actually, January of 1986.
Q It began in January of 1986.
A They began work in December, but the period that I'm
talking about, the intensive work that they carried out, was
in the first six months of 1986.
Q The six months ending June of 1986?
A That's correct.
Q You've also indicated this morning, that you paid
Mr. Fischer $105,000 of that $480,000 in January or February
of 1987. Is that correct?
A That's correct.
Q So is it correct, that in effect, you owed Mr.
Fischer more than $100,000 for a six-month period? He had
coiqpleted his services in June of 1986, but you did not finish
compensating him for those services until January of 1987?
A As I told you earlier in my testimony, our agreement
was for $20,000 a month for 24 months, and within reason,
they could make cash calls along the way, and both that
$50,000 and the ViO^/that.ypiL' ye .384(94 v^f^^llt were the
BtCRSsra
result of cash calls
Q But the services that were being performed for those
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UNtUfiSW
470
monies were completed, in your view, in June of 1986?
A That's correct.
Q Also on page 18, Mr. Miller, there's an indication
of payment to something called Eason, E-a-s-o-n, Associates.
Do you know what Eason Associates is?
A Yes. That's my graphic arts subcontractor.
Q Do you recall a payment to Eason Associates of
$12,000 in June of 1986?
A Not specifically.
Q Were any payments that you made to Eason Associates
payments for services that they rendered to your organization/
A Yes. They all were.
Q Payments for services in the area of graphic arts?
A That's correct.
Q Who was Rafael Flores?
A He's an employee.
Q You will note on page 18, there are indications of
periodic payments to Mr. Flores, the first of approximately
$477, and later, approximately $524.^. Do you recall such
periodic payments to him?
A I'm sure they're salary payments.
Q Salary payments. Now there's also an indication of
two significantly larger payments to Mr. Flores, one in
January 1986 of S5 . 128 ^4^ jm^ A-a.econd on March 11, 1986, of
$6,740.69.
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UNCUSSIHED
471
Do you recall such larger payments to Mr. Flores?
A Not specifically.
Q Well, do you ever recall making payments to Mr.
Flores apart from his monthly salary payments?
A Yes.
Q For what purposes?
A He was the principal escort in the beginning of the
Central American Freedom Program for our speakers, and later,
was one of' several escorts, and he didn't carry any credit
^> ■ —
cards, and he generally travelled with traveller's checks as
opposed to using credit cards, and that's the way he paid his
bills on the road.
Q Well, is it your recollection that you provided
traveljler's checks to him by means of an IBC check payable to
him?
A To him, to cash, or to NBW, or to American Express,
any one of those ways.
. Q Do you have any recollection of any other larger
payments to Mr. Flores?
A Not offhand, no.
Q Turning to page 19, there is an indication of
payments to H-u-m-b-e-r-t-o Q-u-i-n-o-n-e-s. Do you recall
payments to an individual named Humberto Quinones?
Yes.
Who is Mr. Quinones?
UNCUSSIFiED
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UNCUSSinED
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A He is a consultant to IBC.
Q Why were you paying him money?
A For a client matter unrelated to this investigation.
Q A matter that has not relation to your work for the
Nicaraguan resistance?
A That's correct.
Q What is his area of specialty?
A Predominantly the Caribbean and South America.
Q You mean he's knowledgeable about political matters
in that area?
A Political, but predominantly business, trade, and
development.
Q Does he have his own firm?
A I believe he does have his own firm, yes.
Q Do you know what his background is?
A He's a Cuban-American, and he's done work with
several Central American and Caribbean governments.
Q Turning to page 20, there's an indication of a
payment in March 1986 of $6,206.85 to Kemp Enterprises.
Do you recall a payment to Kemp Enterprises?
A Yes.
Q What is Kemp Enterprises?
MlASSm
A That is a producer, whose last name is Kemp, who
produced the "Bitter Legacy" film for us under the Central
American Freedom Program. I can't recall his first name. I
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473
can't remember his first name.
UNCLASSIRED
Q Is it your recollection that there was a payment in
the range of $6,000 in March of 1986 for the preparation of
that program?
A Yes .
Q Who is Kevin Hopkins?
A He's a writer.
Q Do you recall paying Kevin Hopkins $5,000 in the
suiraner of 1986?
A Yes.
Q Why did you pay him that money?
A It was for writing a brochure.
Q About what?
A IBC. Well, Kevin did many things, so I'm not sure
exactly which activity that was for.
Q Did he perform any services in connection with your
work on behalf of the Nicaraguan resistance?
. A No.
Q There's a notation on page 20, Mr. Miller, that IBC
paid $25,000 to the Latin American Strategic Studies Institute
in March 1986.
Do you recall paying such an amount at approximately
that time?
Yes.
IHCUSSlflED
Why did you pay those monies?
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ONCLASSIFIED
474 I
A It was requested by Dr. Calero and approved by
Colonel North.
Q What was the source of those funds?
A That was NEPL money.
Q Who is Gerald McElsay? M-c-E-1-s-a-y.
A I have no idea.
Q There's an indication on page 21 of a $10,000
payment to Gerald McElsay in July of 1985. Do you have any
recollection of such a payment?
A I don't remember the name, Gerald McElsay. I'd
have to go back to my business records.
Q Turning to page 22, do you know, or do you recognize
the name Shokiri Moniereh? S-h-o-k-i-r-i. M-o-n-i-e-r-e-h.
A Yes, but it's inverted.
How should it appear?
Moniereh Shokiri.
Who is that individual?
That is Ibrahim al-Massoudi's wife and business
Q
A
Q
A
partner
Q
Did you make payments to her of approximately
$46,000 in 1985?
Yes.
UNClASSra
Q Why did you make those payments?
A These were payments for office expenses, telephone,
Telex, and fees associated with the al-Massoudi business.
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Q . Now were you reimbursed for those expenses?
A Yes.
Q Colonel North authorized you to be reimbursed for
those expenses?
A Yes.
Q What was the source of funds for that reimbursement?
A NEPL.
Q Now we've talked, Mr. Miller, about your being
reimbursed for the payments to Gary Bagdasarian, and the
$46,000 in payments to Moniereh Shokiri.
There's also a notation, on page 21, of a $25,000
payment to Massoudi in July of 1985. Do you recall that
payment?
A Not specifically.
Q Well, do you recall paying monies to al-Massoudi?
A I don't remember this entry, specifically. It
doesn't refresh a specific recollection.
_ Q Did you keep a record of all of the funds that you
had expended on behalf of al-Massoudi?
A Yes, and we also produced a 1099 at the end of 1986.
Q Did you ask Colonel North, that you be authorized
to be reimbursed for all of the expenditures you had made on
HNClASSra
behalf of al-Massoudi?
A Yes.
Q Did he authorize such reimbursement?
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Q Did you take such amounts out of the NEPL funds?
A Yes .
Q What is your recollection of the total amount of
the reimbursement?
A At this point, it's about 350-sorae thousand
dollars. Our accountants, in their first 1099, missed the
second $50,000 transfer to Bagdasarian, so they reported it
in the 1099 as $291,000, I think, or 290-some thousand, and
actually there was another $50,000 for Bagdasarian. And they
missed one other item, but I've forgotten exactly how much it
was.
Q So it was approximately $350,000?
A That's right.
Q You took approximately $350,000 from the NEPL
funds, pursuant to the authorization from Colonel North?
A My only problem with your using the word NEPL--
there may have been other funds that came back from IC, Inc.
through World Affairs Counsellors, but I couldn't swear to
that. But it was for money for the resistance. It was from
money for the resistance.
Q Now we talked earlier about your discussions with
Colonel North where he authorized you to take a 10 percent
fee for your services in making tjies^ transfers of the NEPL
funds .
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Am I correct in understanding that his authorization
of the reimbursement of the funds you had expended on behalf
of al-Massoudi was in addition to this 10 percent service
charge that he authorized you to take?
A That's correct. I would say that the 510,000 was
as much a reaction to the al-Massoudi business, though. Or
10 percent. Excuse me. And that it was clear to me, after
the business year came to a close in 1986, or '85, that we
were expending an extreme amount of time on this, and going
in the hole, and that wasn't acceptable. You can't continue
doing business that way.
Q Correct. But it was not your understanding that
your reimbursement of the $350,000 that we've been discussing
was to come from the 10 percent service charge that Colonel
North had authorized?
A That's correct.
Q You were to be reimbursed directly on a dollar- for-
doUar basis from the funds transferred to your accounts?
A That's correct.
Q Turning to page 23, there is a reference at the top
to M-o-u-f-i-d, slash, A-r-n-o-u-s . Do you recognize that as
a name?
Who is that person?
UNCLASSIFIED
He's a business partner, associate of al-Massoudi
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Q IS that the correct way that you understand the
name should be written? Moufid Arnous?
A Yes.
Q Do you recall paying him $12,000 at the request of
al-Massoudi?
A Yes. And the second item that you have listed, the
ten thousand, may be the $10,000 associated with the airline
tickets I was recalling, but I'm very hazy on the recollec-
tion.
Q Were payments to Moufid Arnous part of the reimbur-
sement that Colonel North authorized?
A Yes . !
Q Now continuing on page 23, and 24 as well, Mr.
Miller, there is indication of a variety of payments from IBC
to the National Bank of Washington, and I want to review some
of these with you.
First, there is an indication of periodic payments
to. the National Bank of Washington in the range of $5,000,
and another group of periodic payments in the range of $3,000
Do you recall your company making a number of
payments to the National Bank of Washington in tjie 53,000 and
$5,000 range? it^ini IVVV^flT^I
A Not specifically, llg 4
Oil
MR. PRECUP: I think the record should reflect that
in the series to which Mr. Fryman has just pointed
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of the checks seem to be in identical amounts. There are
some checks that are in the amount of 3,000, some in the
amount of five, both with change, if you will, but not what I
think are fairly characterized as periodic payments .
MR. FRYMAN: Let me approach this another way,
then, Mr Precup.
BY MR. FRYMAN:
Q Was the National Bank of Washington the principal
bank for IBC?
A Yes.
Q Did IBC have loans with the National Bank of
Washington?
A We have had two loans, I believe, with the National
Bank of Washington.
Q What was the nature of those loans?
A Business loans. We borrowed money from them, ■aiK
based on future receivables, and repaid it.
Q Did you repay it on a monthly basis or was it a
demand note with the total principle to repay it at a certain
date?
A As I recall, they were both demand notes, and they
were paid in full.
Q All right. So you had no other loan relationship
with the National Bank of Washington other than those two
specific loans you've referred to?j
UNCussra
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A That's correct.
Q Now, did you use the National Bank of Washington in
connection with making tax payments?
A Yes.
Q How did that work?
A We made our tax payments at the National Bank of
Washington.
Q These are employee taxes?
A All forms of taxes.
Q Withholding taxes. And so you made a number of
periodic checks to the National Bank of Washington for that
purpose?
A Well, I don't know how to characterize it, whether
I'd characterize it as "periodic," but I'm sure that's the
form in which we paid our payroll taxes, was by check.
Q All right. By checks payable to the National Bank
of Washington?
A I believe that's correct. I think that's how you'd
pay them.
Q Now other than payments to the National Bank of
Washington for interest on the loan and repayment of the
principle on the loan, and payments to the National Bank of
Washington for various taxes, what other _^
to the National Bank of Was-hington? su^ib]
A None that I'm aware of other than registration
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fees, or standard banking fees.
Q Did you purchase, from tine to time, cashier's
checks or traveller's checks, cr treasurer's checks, at the
National Bank of Washington?
A I'm sure at some time we purchased all three of
those.
Q Now directing your attention again to page 23,
there's an indication of a payment to the National Bank of
Washington in April 1985 of $14,005.1^.
Do you recall a payment in that amount at that
approximate time?
A Not specifically, no.
Q Does that $5 amount indicate to you that that was a
check for the purchase of a cashier's check or treasurer's
check?
A That is possible, but it still doesn't refresh my
recollection.
. Q Well, do you recall the purchase of a cashier's
check or treasurer's check in April of 1985 for $14,000?
A Not specifically.
Q There's also an indication of a payment to the
National Bank of Washington in August 1985 of $18,545.1^ Do
you recall a payment of that amount at about that time?
A That was the payment I had described to you earlier
as one of the a L-iteMfl'tfli^ nMWJBtyfMiUng with the hostage
•vittyint^nFr
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situation.
Q Why was that payable to the National Bank of
Washington?
A I think it was for traveller's checks and they were
transmitted to him in Geneva.
Q Was that an amount that Colonel North authorized
the reimbursement from the NEPL funds?
A Yes .
Q 'There's also, at the bottom of page 23, an indica-
tion of a payment of $20,010 to the National Bank of Washing-
ton on May 15, 1986.
Do you recall a payment of approximately that
amount at approximately that date?
A Not specifically, no.
Q Turning to page 24, there's an indication of two
payments to the Nicaraguan Development Council, one in
December 1985 of $6,000, and one in March of 1986 of $25,000.
Do you recall those payments?
A I recall making payments in that amount to the
Nicaraguan Development Council.
Q Why did you make such payments?
A I can't recall, at the moment, what specifically
they were for.
Q Were these payments made_ _a_t Jj\fi. direction of
Colonel North?
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A If not the direction, at least the approval of
Colonel North.
Q Were these from the NEPL funds?
A Yes.
Q Also on that page, there's an indication of two
payments to Mr. Robelo of $30,000 each, one in July of 1985,
and the other in September of 1985.
Do you recall such payments?
A I recall transferring two $30,000 payments to
Commercial Tooling in Costa Rica, and I was aware at the time
that that was a Robelo organization.
Q Were these transfers from the IBC account?
A Yes.
Q Were these done at the direction of Colonel North?
A Yes.
Q Also on page 24, Mr. Miller, there is an indication
of a payment of $20,000 on January 21, 1986, and our accoun-
tants have not been able to identify the recipient.
Do you recall a payment of $20,000 on January 21,
1986?
Not specifically.
Who is Lawrence Stuart Young?
He's a television producer in Miami.
Do you recall making payments^o him in 1985?
Yes.
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Q What was the purpose of those payments? •■ - . - -
A He was the director and field producer for our
first documentary with Dr. Joachim Maitre.
Q Did those payments total approximately $13,000, to
your recollection?
A Yes.
Q What was the subject of that documentary?
A The freev-om fighters and their military viability,
and their level of popular support in Nicaragua.
Q Was that the documentary that was later revised by
the Robert Goodman Agency?
A Yes.
Q What is ZGS?
A It's a videotape production company.
Q Did you make payments to that company in 1986?
A Yes.
Q What was the purpose of those payments?
A Those were production costs associated with our
multiple client responsibilities, some of them NEPL, some of
them other clients.
Q You described ZGS as a production company?
A That's correct. Videotape production company.
Q Do you mean that they would take a script and they
would film a commercial? Or what would they do?
A "^^^y ■^'MFt #t1^ M-fMV^ri-VIly °^ ^^^ NEPL television
mnviiW»Pf\'
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(202)
conunercials- This is documentary production, credits, film
duplication, editing, general production, videotape produc-
tion.
Q Who is Tony Zumbado?
A He's a producer from Miami who was employed during
the Central America Freedom Program to develop the contra-
film units.
Q What is that?
A He actually had ceunera crews who were resident in
Nicaragua, and Honduras and Costa Rica, whom he retained to
shoot film footage. He was the principal field producer on
the Wesley Smith documentary.
Q You paid him approximately $30,000?
A Yes .
Q What was the Wesley Smith documentary?
A It's called "Bitter Legacy" and it is about the
Sandinista repression of religious and political opposition in
Nicaragua.
Q Is that the documentary that Mr. Young worked on?
A No.
Q So that's a different documentary than the one that
the Goodman Agency revised?
A That's correct.
Q What use was made of "Bitter Legacy"?
A It was crQ'^dflcWit#% iftf fllVn stations on a request
MMSffiff'
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UNCLASSIHED
486
basis,, was put up on. the satellite, and has been used as a
"leave behind" with organizations, television stations, when
speakers spoke to either of those.
Q Do you know whether air time was purchased for
"Bitter Legacy" on television stations?
A I don't ever recall purchasing time on television
stations for "Bitter Legacy. " We did put it up on the
satellite, and you pay for the satellite time, but then the
stations take it and it is up to them to air it, or not.
Q But you're not aware of it being aired as a paid
program?
A I don't recall it ever being aired as a paid
program.
Q Do you recall it ever being aired as a public-
service program?
A Some of the television stations who interviewed
some of the speakers did use it, subsequently, as a public-
affairs program.
Q Public-affairs program. Turning, Mr. Miller, to
page 27 which concerns the IC account in the Cayman Islands,
there is a reference to a receipt in July of 1986 of $55,753.
Do you see that?
A Yes.
Q Are you aware that the IC account received such an
amount at approximately that time?
UNCLASSIHED
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487
No.
I think your record's. incorrect. I think
that's an inter4account transfer which you're attributing to
an outside source.
Q Now our analysis indicates that the IC account
received funds from Herbert Barness, the Heritage Foundation,
IBC, NEPL, and interest payments. Are you aware of any
sources of funds to the IC account other than the sources I
just indicated?
A , No.
Q It's your belief that the entry on this sheet,
dated July 31, 1986, for $55,753, should be an entry for an
inter4account transfer?
>
A Correct .
Q When you refer to " interfaccount transfers," what cy
you mean?
A The managing directors in the Cayman Islands set up
additional accounts in order to draw interest without our
direction. They simply took it upon themselves to do it, and
when we would require transfers to be made out, sometimes
they would have to accumulate the sum in one of the accounts
and they did that by transferring the amounts from other
accounts. And I' believe your entire bottom section probably
is redundant to tiie.lJSQ ^egt^n. __So^'m very dubious about
your analysis .
Q Turning, again, to page 32, we've talked earlier
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today about the indication of a payment from Miller Communica-
tions to Kate Macinnis in March of 1986 for $31,663.00.
I believe you indicated that that was for some
purpose other than a direct payment to Kate Macinnis.
A That's correct.
Q I believe it was for a purchase of a cashier's
check or a treasurer's check, or some other sort of transfer.
Is that correct?
A Some other form of transfer. That's correct.
Q Do you have any recollection of a payment or a
transfer in that amount from Miller Communications in March
of 19867
A No.
Q If you will turn to page 33, there is an indication
of a transfer from Miller Communications to the National Bank
of Washington in December 1986 of $64,791.04.
Do you recall a transfer in that approximate
amount, or a payment in that approximate amount in December
1986?
A Again, I'm sure it was for some instrument of some
sort, but I don't specifically recall. It could have well
been year-end draw. Something that will cheer the IRS.
Q Now going back to page four of this exhibit,
there's an indication, Mr. Miller, that in 1985 and 1986 —
le total figure combined for 1985 and 1986?
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489
Q For 1985 and 1986, yes. This analysis covers
January 1985 through December 1986, and it indicates payments
to IBC from NEPL of $5,037,751,101
Is it your recollection that in that two-year
period/ IBC received payments from NEPL in the approximate
amount of $5 million?
A I can't attest to that figure without going back and
looking at my business records.
Q 'I'm not asking you to attest to that figure. - My
question is, is it your recollection that in that two-year
period, the total payments to IBC from NEPL were approximately
$5 million?
- A Approximately $5 million, yes.
g Is that correct? That's your recollection?
A Yes.
Q Now, in addition, page four indicates that IBC
received a payment from the Western Goals Foundation of
$6^762, which we discussed earlier today, and you indicated
that you recall a payment in approximately that amount from
Western Goals, is that correct?
A Tes.
Q Page four also indicates that IBC received payments
from the American Conservative Trust of $11,440. Is it your
recollection that in this two-year period, IBC received
payments from the American Conservative Trust in approximately
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that amount, of $11,4407
A I don't specifically recall the amount, but I recall!
receiving compensation in rough approximation of that figure.
Q From the American Conservative Trust?
A Yes.
Q There's also an indication here of receipts by IBC
of $21,000 from the Palmer National Bank. Do you recall any
receipts from the Palmer National Bank, or do you have any
explanatidn of — well, let me leave the question. Do you
recall any receipts in the range of $21,000 from the Palmer
National Bank?
A Not from the Palmer National Bank. That would have
been money from the National Endowment for the Preservation
of Liberty.
MR. PRECUP: Mr. Fryman, before you leave page
four, I would like it noted for the record/ I have a strong
objection to the indication of the words "income" on this
page because it is not consistent at all with Mr. Miller's
testimony nor with the records themselves, or, I think the
facts, that that is income in any income tax, or even
financial sense. It may have been receipts. But the income
characterization is wholly improper and without foundation.
MR. FRYMAN: Well, Mr. Precup, I'm not asking that
Mr. Miller adopt this exhibit in any way, and in the prepara-
tion of this exhibit, T Ji hi" l_ljnki#«i>'<nil our accountants
miMi^^trnn'
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491
intended to suggest by the word "income" that the amounts in
that column were taxable income.
I think the word on the cover page, in analysis 3A
is "receipts "yi and I think what you're saying is that you
would have preferred that the word "receipts" be used on page
four as well.
Is that correct?
MR. PRECUP: Well, I didn't say that. I said I
objected to the use of the word "income."
MR. FRYMAN: Well, your objection is noted.
MR. PRECUP: Thank you.
MR. FRYMAN: As I say, I'm not asking you or your
client to accept the characterization, and there is not any
intent in preparing this to suggest that these amounts were
taxable income.
MR. PRECUP: Thank you, Mr. Fryman.
BY MR. FRYMAN:
Q Mr. Miller, in Exhibit 29, there is a reference in
several places — and to take an example, page 7 of Exhibit 29-
-to Carlos Ulet, U-l-e-t. Do you recall a payment to an
individual by that name?
A Yes. But it's incorrectly reported as Ulet.
Q what is the correct spelling?
A It's pronounced Ulvert, and it's u-1-v-e-r-t.
Q Who is Carlos Ulvert?
yiisussinED
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A . He is th«— or was the executive dl^nctor- .and
Washington representative of UNO, Unified Nlcaraguan Opposi-
tion.
MR. FRYMAN t Off the record.
[Discussion off the record.]
MR. FRYMAN: I ask the reporter to mark as Miller
Deposition Exhibit 30, a composite exhibit composed of a
group of pages produced by counsel for Mr. Miller, and IBC.
(The document referred to was
marked Miller Deposition Exhibit
No. 30 for identification.]
MR. FRYMAN: The first three pages of this exhibit
is a handwritten inventory of the materials Included in the
exhibit, identifying, where possible, the date of the
document, and the control number of the document, placed on
the document by counsel for IBC, and Mr. Miller.
■?
MR. PRECUP: Those are our control numbers.
MR. FRYMAN: They're your control numbers.
MR. PRECUP i Thank you.
[ Pause . ]
BY MR. FRYMAN:
Q Mr. Miller, I show you Deposition Exhibit 30 for
identification. Mr. Miller, if you *rould first look at the
documents included in Exhibit 30, which begin with your
control number 1377. It'
I
mm
cal event checklist
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dated. .March 1, 1985. There then follows, beginning at your
document number 1357, a chronological event checklist dated
March 15, 1985.
After that, there is a chronological event checklist
dated March 20, 1985 which begins with your control number
1368.
Then at page 1385, there is a document headed
"Congressional/Public Affairs/Diplomatic Action Plan."
•MR. PRECUP: Mr. Fryman, Just a moment here. We
seem to have a page or two missing. The previous chronologi-
cal checklist that you identified was our control number
1368, March 20, 1985.
That appears, on our copy, to be a two-page
document. It is followed by control number 136 — and obliter-
ated— I think it's probably 1369, that starts on page two and
continues. So its dates appear not consecutive with those of
its preceding pages, and we may be missing a cover sheet.
MR. FRYMAN: Mr. Precup, I believe you are correct.
MR. PRECUP: Is your copy the same way?
MR. FRYMAN: It is.
MR. PRECUP: The document to which I just referred
beginning on what appears to be 1369, continues through
serial number page 9, and then you just, if I recall correct-
ly, directed our attention to 1385.
MR. FRYMAN: Xss . ^Tid Af^ mwmimnes through your
TiMi^iK^onm'
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control number L376., ..
MR. PRECUP: Okay. The one that begins, yes, on
page two .
MR. FRYMAN: On page two.
MR. PRECUP: All right. Fine.
MR. FRYMAN: There may be missing, in this exhibit,
the first page of that document.
Then, at page 1385, as your control number, as I
indicated; there's a document headed 'Congressional/Public
Affairs/Diplomatic Action Plan."
MR. PRECUP: Hay I ask about that document, Mr.
Fryman, please. Ours is marked "confidential." There's no
indication of a removal of a security —
MR. FRYMAN: Mr. Precup, that was as produced by
you.
Then, beginning at your control number 1389,
there's a document dated April 17, 1985, headed "Calendar of
Events Regarding Nicaraguan Resistance," which appears to be
a t%ro-page document, and finally, at your control number page
1391, there is a document dated ^ril 16, 1985, which is
headed "The 208 Group."
On each of these documents, where there is a
confidential stamp, that stamp was on the document when it
was produced your firm, as counsel for Mr. Miller and IBC.
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Q Now the documents that I have just identified, Mr.
Miller, do you recognize those documents? Have you seen them
before?
A I've seen them before.
Q Where did you obtain those documents? And if you
obtained them from different sources, would you identify the
source for each. If you obtained them all from the same
source, if you would just identify the one source.
A I can't tell you specifically who provided me with
them. I believe they all came from the same source and it was
probably Jonathan Miller at State Department, or possibly
Oliver North, but I don't ever remember Ollie North giving me
copies of a document like this.
Q Did you ever discuss these documents, or any of
these documents with Oliver North?
A I don't remember a specific discussion with Oliver
North about these documents .
Q Did you ever discuss these documents with Jonathan
Miller?
A Again, I don't have a specific recollection of
discussing them with Jonathan Miller.
Q Is it your best recollection that you obtained
these documents from Jonathan Miller?
A It's my best recollection that I got them from
either Jonathan Miller or Olivet Nprt,
or Olivet North '^^Lf^ag , and I don't
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remember specifically who gave them to us.
Q Do you know who prepared these documents?
A No. I don't.
Q Do you know if Pat Buchanan had any role in
preparing these documents?
A I don't know who prepared them. I'm not aware of
any role by Pat Buchanan.
Q Did you ever discuss these documents with Pat
Buchanan? .
A I don't think so.
Q Did you ever meet with Pat Buchanan?
A I've met him one time, I think.
Q That meeting had nothing to do with these documents?
A No.
Q What did you understand was the purpose of these
documents ?
A They were a reflection of events taking place in
Washington, in the United States, that impacted on the
Congressional vote for aid to the freedom fighters.
Q Now, on the first page of this group of documents,
the chronological event checklist dated March 1, 1985, which
has your control number 1377, at the top, under the "Respon-
sibility" column, there is a reference, "State/LPD," and then
parentheses, (Miller), close parentheses.
Now, in March of 1985, were you and your company.
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IBC, performing services for the State Departmeat pursuant ta
a contract?
A Yes.
Q Was that contract with the LPD office of the State
Department?
A Yes.
Q Now was it your understanding, that the reference
to Miller in the "Responsibility" column under State/LPD, was
a reference to you?
A No.
Q Who did you understand that referred to?
A Jonathan Miller.
Q What was the reason you believed that referred to
Jonathan Miller instead of yourself?
A Because in other locations where our company was
referenced, they usually put Gomez as opposed to putting
Miller, and a couple of these things that are attributed to
Jonathan Miller, we did not have any involvement in, such as
the very first one on the list.
We didn't send out the resource book on Contadora.
That was done by somebody other than us.
Q So, then, as an example on the next page, 1378, at
the bottom of the page, again in the 'Responsibility" column,
there is a reference to State/LPO, and under that, paren,
at you just
(Gomez), close paren. Is that an exa
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referred to, of an indication of actions to be taken by IBC
and Mr. Gomez, and you, pursuant to your contract with the
State Department?
A Well, it's action taken by Mr. Gomez. I'm not sure
that is activity expected under the State Department contract.
As you can see, in that same entry it also talks about Dan
Kuykendall and Dan Kuykendall was not a contractor for the
State Department.
' There are many other people in this document that
are in no way connected to the Federal Government. So this
document seems to have relied on a number of people outside
government to also take certain actions .
Q So the reference to Gomez on page 1378 is unclear
in your mind, whether that's a reference to your duties under
the State Department contract?
A Actually, no, I would say it's quite clear in my
mind, that we did not set up the Bermudas, Tegrio, and Mike
Liiga news conference — although I don't even remember Mike.
Mike Lima was not at the news conference — on behalf of the
State Department. That was done with Dan Kuykendall, the
Gulf and Caribbean Foundation.
Q Would you look through these pages and point out to
me an example of the sort of entry you referred to where
there is a reference to Gomez, and that means work under the
IBC contract with the State Department
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MR. PRECUP: If there is one.
[Pause. ]
THE WITNESS: On page 1380, at the very bottom,
there's a reference to a Pentecostal minister, who name is
Vallardo Antonio Santeliz, and he was somebody that Frank
Gomez provided escort services for, and for whom we set up
some press interviews.
BY MR. FRYMAN:
Q -That was work you were doing pursuant to the State
Department contract?
A Yes.
Q Now in that entry, there's also a reference to Mr.
Kuykendall, who you indicated earlier you did not believe was
working pursuant to a government contract.
Do you have any understanding as to why Mr.
Kuykendall is referred to in that sane entry?
A Yes. In our contract, we would try and find an
org.anization to sponsor these refugees or these atrocity
victims, and in this case, the Gulf and Caribbean Foundation
agreed to sponsor this individual.
Q All right.
A On page 1381, there is a reference to Miller/Gomez
for Pedro Juaquin Chamorro — misspelled — editor of "La Prensa"
for a U.S. media and speaking tour, and that was an activity
handled under our State Department contract ^^^jri'j alV% '' ^-
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Q Now did you understand the reference to Miller in
that entry to be a reference to you or to Jonathan Miller?
A Jonathan Miller. I don't think there are any
references to me, personally, in this document.
Q Now, at this time in 198S, what was Jonathan
Miller's position?
A I believe he was still the deputy director of the
Office for Public Diplomacy.
Q ' He was an employee of the State Department? -
A I believe that's correct, yes. Did you want me to
continue?
Q No. You've answered my question. Do you know why,
Mr. Miller, that Jonathan Miller, as an employee of the State
Department, would be distributing a document, which at page
1383 have your control numbers — refers to the beginning of a
"targeted telephone campaign" in 120 Congressional districts,
for Citizens for America, district activists, organize a
phgne tree to targeted Congressional offices, encouraging
them to vote for aid to the freedom fighters in Nicaragua.
MR . PRECUP > Excuse' me , Mr . Fryman . Did you say
why Jonathan Miller would have been undertaking that?
MR. FRYMAN i I think the question was do you know
why.
MR. PRECUP t Well, but I don't see Mr. Miller's
name on this pages ■vwUtfim|p#)A4:^|C'\n the antecedent of
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your question there. Why do you put in your question Jonathan
Miller, when I don't see his name on the page?
MR. FRYMAN: Well, Mr. Richard Miller indicated that
he believed this document had been distributed to him by
Jonathan Miller. !
MR. PRECUP: Oh, I think his testimony was not
quite that. I think he said it was given to him by one of twol
people, or one or two offices, and he wasn't sure which. Mr.
Abramoff's name appears on this event list on page 1383, not
that of Miller, Jonathan or otherwise.
MR. FRYMAN: Well, that's true, Mr. Precup. |
Let me ask some further questions .
BY MR. FRYMAN:
Q Is it your understanding that Jonathan Miller had
any responsibility for the preparation of this chronological
event checklist that we're discussing?
A I believe he did, yes.
_ Q All right. Now let me now ask the question that I
asked a minute ago. Do you have any understanding as to why
Jonathan Miller, as an employee of the State Department,
included in this checklist the item with regard to a targeted
telephone campaign that appears on 1383?
A I have no idea why he included it.
Q Did you ever discuss that with Jiiffl?,
A No .
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Q Did it. surprise you to see that item on a docxunent
that you understood was prepared by an employee of the State
Department?
A I don't remember being surprised.
Q Mr. Miller, turning to your control number page
1391, which is the April 16, 1985 sheet headed "208 Group,"
what was the 208 Group?
A I'm not really sure.
Q >Was that a phrase that you ever used in conversa-
tions at this time?
A No. The only time I ever heard it was one day Fawn
Hall used it. And I said who's that, and she ticked off a
whole bunch of names, about seven or eight of them, and I
remember I wrote them do%ni. In fact, I produced that piece
of paper to you. It was Will Ball and some other folks.
Q Do you know why your files contained pages such as
page 1368 and the pages following that, which is the March
20^ 1985, chronological event checklist, which have a
confidential stamp on thera?
( Pause )
A I have no particular explanation as to why. They
simply were provided to us.
Q And you believe that was by Jonathan Miller?
A Again, I believe it was by one of two offices,
either Jonathan Miller 'A ptfXoi fiSi^Uti.ir«ii»W«nh ' s office.
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I also notice that there is on 1385 what seems to
be an indication about declassifying. I don't know whether
that means these were declassified or whether this is the
office in charge of declassification.
Q And following that are the initial OADR?
A Yes.
Q Do you know what that refers to?
A No.
Q Turning in this exhibit, Mr. Miller, to the
document that has your identification No. 2433 and 2434,
which is a memorandum for Mr. Robert C. McFarlane of the
White House — and this is a document that has been discussed
to some extent previously in this deposition — that is a
document that you prepared, is it not?
A It is a document which I contributed to in a large
percentage, and I believe by telephone, if I recall correctly.
Q Tou mean you dictated it over the telephone?
_ A Yes, I think that was the way it was done.
Q Who did you dictate it to?
A I don't remember. I think it was somebody over at
the State Department.
Q In Jonathan Miller's office?
A I believe so.
Q And the second page, headed "Contributions," did
you also dictate that information?
immm
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A Yes.
Q And the handwriting on that page, is that your
handwriting?
A Yes.
Q Do you know how you happened to receive a copy of
this document back for your files if you dictated it to Mr.
Miller's office, Mr. Jonathan Miller's office?
A Well, I think that you see is a draft copy which
came to m4, and I subsequently made recommended changes) and
I don't think I have the final copy in my file.
Q What did you do with the copy after you made the
recommended changes? Did you transmit the revised copy to
anyone?
A I'm sure I did, but again I don't remember who
specifically it was. But I think it was whoever I dictated
the original document to.
Q So you believe you sent it to Jonathan Miller?
- A Again my recollection isn't complete on this. But
I think that's the office that was handling this. And I
can't remember the individual who I was dealing with over the
telephone.
Q Would you have sent this to Oliver North?
A That's possible.
Q Now, there's a reference in the memorandxim to a^
meeting on Tuesday, June 25, or Thursday
ihe memorandum to a ,
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Is that June of 1985?
A That is correct.
Q And would this memorandum have been prepared by you
a few weeks prior to that, or in early June or in May of 1985?
A Yes.
Q Why did you believe it was appropriate for the
Department of State to request a Presidential meeting with
Mrs. Newington? Because she had made substantial contribu-
tions to programs designed to support the policies of Ronald
Reagan?
A Well, her contributions went beyond just supporting
policy. It included a large number of political and humani-
tarian gifts as well. Any one of those I feel would have
qualified her for the appointment. In fact, we found it sort
of extraordinary that she hadn't been to meet the President
prior to this .
If you go into the Roosevelt Room, the paintings
tha£ hang on the wall, and if you go into the family quarters,
the paintings that hang on the wall, millions of dollars
worth of paintings were given years ago by she and her
husband. So she has been a long-time supporter of the United
States Government, and has given both to political and
humanitarian activities. And so, for those reasons, she
deserved an opportunity to meet the President.
Q But, in this memora
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request by the Department of State for a Presidential meeting
with Mrs. Newington is described to be the contributions that
are attached to the mefflorandum, is it not?
A That's correct.
Q And my question to you is why did you believe that
it was appropriate for the Department of State to recommend a
Presidential meeting on the basis of these contributions?
A Well, it is, as I understand it, fairly standard
practice for agencies and departments, the senior staff in
those agencies and departments to recommend people to meet
both the President and the Vice President and other in-
dividuals when they deserve some recognition as citizens.
And that's exactly what was happening here.
Q Turning to the page with your Control No. 3572,
which is a calendar for August 26, 1985, do you recognize
that calendar?
A Yes.
Q Are the notations on that calendar in your handwrit-
ing?
A Yea.
Q Now, there's a reference on August 26th to a
meeting with Roy Godson at 10:30.
Do you see that reference?
A Yes .
Q Do you recall what that meeting involved?
UNCLASSIFIED
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A Ye«. I testified earlier that this meeting was to
discuss a grant from, at that point, unknown to me, a
contributor who turned out to be the Heritage Foundation.
Q Was that a meeting that you had at Mr. Godson's
office?
A That's correct.
Q What does 17 30 RI refer to?
A That's Rhode Island Avenue.
Q . Is that the address of his office?
A Yes.
Q And is 601 the office number?
A Yes.
Q Was this the first time you had met Mr. Godson?
A I believe so, but I'm not certain of it. I had two
meetings with him in his office, and I don't know whether the
second was recorded in my notebook or not.
Q But other than the two meetings with respect to
this matter, you had not previously meet Mr. Godson?
A No.
Q Who put you in touch with Mr. Godson?
A Oliver North.
Q Did he tell you that Mr. Godson would be calling
you?
I honestly don't remember how it was left, but we
o I don't know
were to have a phone conversation rin iiiin 4 iiilin
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who called who.
Q Turning to the next page, which is 3120 is your
control number, and it's a memo to you and Frank Gomez, dated
September 30, 1985, from Dan Conrad, there's some handwriting
on that sheet.
Whose handwriting is that?
A Mine .
Q There are various requirements for the month of
October described in that memorandum, including an RR letter
to Barbara Newington and an RR meeting with Barbara Newington,
and an RR meeting with Bunker Hunt, Ellen Garwood, Fred
Sacher, and the Warms. After that, you have written the word
" green . "
what does the word "green" refer to there?
A Colonel North.
Q And does that mean that Colonel North was to
arrange those items?
A No. It meant that I wanted to — it was a mental
note to myself to talk to Colonel North about it.
Q Did you?
A Without a subsequent checkmark and hashmark through
it on this page, I don't see any indication I did. If there
was a phone conversation with him or a meeting in which it
was discussed, it would appear some place else, and itwould,
probably be one of those marks through i
:e else, and it would _.
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I think this is just my reacting to Dan Conrad as
he was explaining the things on my list, and my thinking
about who I would go to see about it .
Q So when they asked for a letter or a meeting with
President Reagan at this point in September of 1985, it
occurred to you that Colonel North was the person you would
go to to arrange such a letter or meeting?
A Well, that, and I would never undertake to have a
meeting like that without letting Colonel North know that we
were doing it. It would have been folly for us to do that.
Q Well, was the notation here merely that you were
going to notify him that you were going to try to do this, or
was it a notation to indicate that you were going to attempt
to arrange these events through him?
A I think those are only notations that I intended to
discuss it with him. I don't think it indicates that I was
going to ask his assistance or just inform him, but that I
waft intending to discuss it with him.
Q At this point in time in September of 1985, whom
would you contact to try to arrange a meeting with President
Reagan for Barbara Newington?
A I might have contacted the Public Liaison Office or
the Political Office?
Q Who?
A John Roberts, Lynus Cochelus. In fact, some of the
ilASSIRM
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briefings that we set up were set up through the Public
Liaison Office or through the Political Affairs Office.
Q Are these briefings with President Reagan?
A The initial briefing with President Reagan, the
recononendations began in the Public Liaison Office.
Q When you refer to the initial briefing with
President Reagan, to what are you referring?
A January 27th, I think it was, 1986.
Q Could that have been January 30, 1986?
A 30, you're right, 30.
Q Now, is it not true that David Fischer had a role
in arranging that briefing?
A He did. But again I think the original formal
request started also in Public Liaison.
Q But is it your understanding that David Fischer was
the person who was responsible for arranging that briefing?
A He had principal responsibility for it.
Q Now, before David Fischer was involved with your
organization, who had the principal responsibility for
attempting to arrange meetings with President Reagan?
A There was a shared responsibility between Mr. Gomez
and myself. I'm sorry, I reacted wrong to your question,
because I didn't hear you drop President Reagan at the end of
your question.
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responsibility. The only other meeting we- attempted to get
for the President was the Barbara Newington meeting, and I
had responsibility for that memorandum.
Q And with whom did you arrange that meeting? You
mentioned Jonathan Miller.
A Again, I've forgotten who exactly we gave the
original text to. But I believe the memorandum came out of
the State Department and went to Robert McFarlane, and then
was signed off by people within the National Security Council.
Q Did you seek the assistance of Colonel North in
arranging that meeting with Barbara Newington?
A He was aware of it, yes.
Q But did you also seek his assistance and support
with respect to that meeting?
A Yes .
Q Now, turning to the next page in this composite
exhibit, Mr. Miller, which has your Cffi@|^^HBf462i9Pne
writiit^psoa^rinting appears on that page?
A Mine.
Q Did you draft this letter?
A Yes, I did.
Q And then if you will look at the subsequent pages,
2887 through 2889, those are letters dated December 17, 1985,
from Oliver North to Frank Darling^t^n,;_(lS.lvin Salwasser and
Bill Bush.
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Now, those Letters . -appear to be- the text that you
drafted at 4462, is that correct?
A That's correct.
Q Did you send that text to Colonel North for him to
send those three letters?
A I sent him that as a recommended text and these
names and addresses. And I believe it's not completely
identical. I think he changed it to suit his needs and
signed them and sent them to the people.
Q What were the changes that Colonel North made?
A I think he left out the word "Nicaragua" after the
word "democracy" in what was my final sentence. And he put
"may God bless" in the body of the letter and used "Sincerely"
as the salutation.
He basically adopted the text you proposed, did he
not?
Yes.
And then he sent you copies of the letters?
Yes. Actually Fawn Hall sent them to me.
Now turning, Mr. Miller, to the document with your
Control No. beginning 2665 through 2687, which was a series
of letters from Colonel North, dated January 24, 1986.
Did you draft the text of those letters?
A Basically, yes.
At page 2
im^RFS'
s an address list
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and an indixration of the proper salutation for. the letter.
Were those pages prepared by your office?
A I'm not sure whether the salutation and address
pages were prepared by our office, but they were certainly
supplied to Colonel North either through us or directly by
NEPL. I've forgotten which.
Q They were prepared either by you or by Mr. Chan-
nel's office?
A • Correct .
Q And you drafted the letter?
A Yes.
Q What was the procedure for arranging for Colonel
North to send this letter?
A I either met with him or had a conversation with
him about the need to send a thank you to the people involved
in the NEPL efforts. And he agreed, if I would give him a
draft, that he would send them thank you letters, which he
did.
Q And then he sent you copies?
A Yes.
Q What was the need to send letters to these in-
dividuals, as you understood?
A They were people who had contributed to the public
education program of <C!>iiiuiiUi(!i% Endowment for Preservation of
Liberty, and were being r<
and were ^^Ji9^§60§§i-9^
for that contribution.
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Q Was another purpose o£ this letter to prepare thejn
for a further solicitation by Mr. Channell's organization?
A That wasn't my purpose when I asked for them. They
were simply recognition of contributions to the public
education effort.
Q What did you mean by the phrase, and I'm assuming
that you wrote this phrase, but if you did not, correct me,
in the last paragraph, or in the next to the last paragraph
of the letter which states, "In the weeks ahead, we will
commence a renewed effort to make our assistance to the
Democratic Resistance Forces even more effective. Once
again, your support will be essential."
Did you draft that phrase or those sentences?
A I don't recall whether that was specifically in my
draft that I sent to Colonel North. But, in general^J*gg» I
think it refers to the coming political debate associated
with assistance to the f^reedom fighters .
Q Were these individuals that you knew were going to
be invited to the briefing at the White House on January 30,
19867
A It's a different year. I'm sorry, you're right,
you're absolutely right. I'm sorry.
No, I don't think that was the intended purpose of
it.
Q Did you expect tji^x X^Sfib^idd' vidua Is would be
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solicited, again by Mr. Channell for the Central American
Freedom Program which was getting underway in January of 1986?
A I'm not being flippant. Don't misunderstand me.
Of course. I don't know one fund raiser that doesn't go back
and solicit contributors time and time again, depending on
whether they provide money for a program prior to it, and
that's standard operating procedure for political organiza-
tions and fund raisers.
Q Turning back, Mr. Miller, to the two pages in ■
advance of the first of the January 24, 1986, letters, which
are pages 15026 and 15027, do you recognize those pages?
A Yes.
Q Where did you get those pages?
A From Citizens for America, I believe.
Q Do you recall when you got them?
A Yes . We used to go and attend the general strategy
sessions held either by Colonel Sam Dickens over at the
American Security Council, or by Dan Kuykendall. And in each
of those meetings, the Citizens for America people would hand
out an updated list of their Congressional targets.
Q What representative of Citizens for America would
hand out this list, or a list such as this?
A Peter ri^iiic^ I think was the one I remember.
There may have been others .
Q
iTCjWi5^(*Tflrn
a the group that was headed
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by Lew- Lehman? — - -
A Yea . I would mention also that there was ray
handwriting on this list, and what that is is a reflection of
a discussion with Dan Kuykendall where, in some cases, he
didn't agree with their characterization of people as targets
or. And sometimes I would take their list and compare it
with what knowledge Dan Kuykendall had, and I think that's
the note you see on it.
Q . At pages 53034 through 53036, there are documents
relating to the Heritage Foundation grant which we've
discussed today, and which Mr. Kaplan has questioned you
about at a previous session.
This list of gran^ was it not, that was the
subject of your meetings with Mr. Godson?
A Yes .
Q Did Mr. Godson tell you that he had been asked by
Colonel North to raise funds ford
A Mo, I don't think specifically I've been told that.
Q What did he tell you?
A He told me that he had a contributor who wanted to
give money to the Democratic Bfeslstance, and that they did
not want to give money to Mr. Channell specifically. And I
came away from my meetings with him with the sense that this
contributor was^logi^ing ^o^cQv^dfidDoney to political
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entitxea and the non^comBative segments of the opposition.
Non-f combatant, I should say, segments.
Q Colonel North asked you to meet with Mr. Godson,
did he not?
A Yes.
Q And did you understand your role with respect to
the funds being raised by Mr. Godson was to provide vehicle
for receipt of the funds?
A That's correct.
Q Did you discuss with Mr. Godson two alternative
vehicles, one being the Cayman Islands bank account, and the
second being the Institute for North-South Issues?
A I remember discussing the Institute because that's
what I later recommended to him. I remember discussing Mr.
Channell, and I may have told him that somebody could give a
contribution directly.
Q To the Cayman Islands account?
A I don't recall where I told him, but I may have
said that somebody could have given a contribution directly.
Q Now, is it correct that, at a later point, Mr.
Godson had a discussion with you about using the Heritage
Foundation as a vehicle for the contribution?
A I don't recall a subsequent conversation, although
I may have called him and somewhat surprised at the correspon-
dence I receJc;nll4W> k^A Atff^^l^Ilou'^^^^lon asking for a
' rtTMnra^!siFiFr
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grant. I don't think I left his office knowing that it was
the Heritage Foundation.
Q Is it your recollection that the first knowledge
you had of the involvement of the Heritage Foundation was the
receipt of a letter from the Heritage Foundation?
A That's my recollection, yes.
Q After receiving that letter, did you then have a
conversation with Mr. Godson?
A ,As I said a moment ago, I don't remember a specific
conversation. But I have a sketchy recollection of calling
to express some surprise at the letter from the Heritage
Foundation.
Q Did you have a discussion of this letter from the
Heritage Foundation with Colonel North?
A I don't recall whether I did or not.
Q Did you ever discuss in any way with Colonel North
the use of the Heritage Foundation for transferring contribu-
tions to entities associated with Nicaragua?
A I don't recall having such a conversation with him.
Q Did you have a conversation with Dr. Edwin Feulmer,
F-e-u-1-m-e-r, about a grant from the Heritage Foundation?
A If I did, I don't recall it. I don't recall having
a conversation with him about it.
Q On your file memorandum, dated December 1, 1986,
which is your 0<i4M>flVt VRCftHi'H 41^ memorandum which you
""WJEsra*
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OHCLASSIFIED
prepared, is it not?
A Yes .
Q In the first paragraph, you state that the grant
was provided to INSI at the request of the National Strategy-
Information Center.
How did you learn that?
A That's Mr. Godson's organization.
Q Yes . But who informed you that the Heritage
Foundation grant had been provided to INSI at the request of
the National Strategy Information Center? -^^
MR. PRECUP: He just answered that, Mr. Fryman.
THE WITNESS: Yes. I don't know how else to answer
it. Mr. Godson was the head of the National Strategy
Information Center. I went to see him about the grant, and
subsequent correspondence came from the Heritage Foundation.
BY MR. FRYMANS
Q Well, in your initial conversation with Mr. Godson,
there is no mention of the Heritage Foundation, is that
correct?
A Right .
Q Then you got a letter from the Heritage Foundation •
A Right.
Q — talking about a grant.
Now, I'm not clear from your testimony that after
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the receipt of the letter from the Heritage Foundation, you
had any further communication with Mr. Godson.
A Well, I'm not clear in my recollection about
whether I had any subsequent conversation with Mr. Godson
about it. But I seem to recall calling Mr. Godson and
expressing some surprise about the Heritage Foundation letter.
So I think that statement that you just read, the
grant was provided to INSI at the request of another 50103
organization, is in keeping with what I just told you..
Q So it's your belief that — your basis for that
statement as a conversation with Mr. Godson after you got the
letter from the Heritage Foundation, is that correct?
A Yes.
Q That's what I was trying to clarify.
Now, in the third paragraph, you state that INSI
retained a 20 percent administration fee for its distribution
of this grant. And you go on, all other expenditures, and
the memorandum reads where, but I think that's a typographical
error, I think it should read were —
A Correct .
Q — made through Latin American nonprofit organiza-
tions .
And the paragraph earlier refers to an investigation
and analysis of information available to international news
organizations .
iformation available to ir
UNCLASSIFIED
527
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What other Latin American. nonprofit organisations
were making expenditures in connection with this grant?
A Well, anybody involved in the Nicaraguan Resistance
is a nonprofit organization. And anyone involved ^i^^^lH
UH|Bor the Democratic /Ilesistance political entities is a
nonprofit organization. So I would have viewed any of those
entities as nonprofit.
Q Did you understand there was an investigation and
analysis of information available to international nevrs
organizations that was being undertaken as a result of this
grant?
A I would say that that is a simplification of what I
thought the money was to be used for, and that as for the
generation of news reports and information on political
activities by those organizations.
Q Nhat do you mean by the generation of news reports
by those organizations?
A Nell, any political entity or human rights organiza-
tion or entity associated with a political movement that
najgi^eii/ communicate with the public and the world at large.
And they do that through the media.
Q Mr. Miller, in this composite exhibit, a group of
telephone messages begins at the page with your Document
Control No. 3133.
0« di^t%^|a V jVlV^!^!^T^<'^" ^° y°^ i'o^ ^awn —
ifl(jmoT^?^n'
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3131.
yNCLASSIFlEO
Q 3131, I'm sorry.
— dated 9/17, which states give her a call re a
Texas based group called Freedom's Friends. She wants you to
do a little background check on them for Ollie.
Did you understand this message came from Fawn Hall?
A Yes.
Q Do you recall this message?
A • Yes .
Q What did you understand you were being asked to do
here?
tion.
To find out whether this was a legitimate organiza-
Q How would you go about doing that?
A Calling friends and associates. I don't think I
did anything with this one though.
Q Did you consider this an unusual request by Fawn
Hall on behalf of Oliver North?
A No.
Q Did you receive similar requests on other occasions?
A Yes.
Q Turning to the next page, 3149, there is a message
to you from Fawn, dated 4/9, which says has package which
must be picked up today, and it continues regarding AAA
meeting tomorsvi, ■ liCU ^ti<3iiXtL JifQKi^J^on
mm mmti'
igh Bob Ma^n.
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Do you recall receiving that message?
A Not specifically, but it's got my hashmark through
it and that's what I do with my phone messages when I read
them. So that means I looked at it or acted on it.
Q Do you believe the date of this message was April
9, 1986?
A I'm really not sure.
Q Who was Bob kmSmta?
A
the State Department in '86 but not in '85, so it would have
to be 1986.
Q Well, what was his position in the State Department
in 1986
A
Oh, it would have to be 1986, because -iU^^^was in
A
t/
He was originally a deputy to Elliot/Abrams,
actually an assistant to Ellioj^^rams, and then became the
Coordinator of the Office of Public Diplomacy.
Q Now, what does the AAA meeting refer to?
. A Adolf o Calero, Arturo Cruz and Alfonso Robelo, and
it probably had to do with meeting the President. I can't
recall whether there was a meeting on that date or not, or on
or about that date.
Q And is that an example of an activity that you
would work with Mr. ToJgon on?
A No, not generally. This again doesn't bring to
mind any sp^cjj i<^^ct^^^^t^f^.f wtm^ tke only other time I met
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with. Mr. K<i«g«n on Msiatanca leaders was to. discuss-some
politics associated with the leadership and a subsequent
meeting I have already recounted to you in previous testimony
for the establishment of an Uno Office.
Q Do you recall what the package referred to in this
message is?
A No, I don't remember.
Q Turning to the next page, which is 3161, there is a
message again from Favm, which states that Fawn received a
message that a Huck Walter in Staunton ^^^^^^^^B ^" looking
for a contra to 'pressure his district.* Fawn doesn't know
if Staunton is Virginia or not.
Do you recall that message?
A Yes, I think so.
Q What did you understand pressure his district
referred to?
A As I recall, this gentleman wanted a contra to come
in and condemn his opponent. And we turned him down.
Q Did you understand Mr. Walter was a candidate for
Congress?
A I've forgotten whether he was the candidate or
whether he was working for a candidate. But he was quite
angry with me.
Why did you turn him down?
Because it was inappropriat
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Q Why?
A It was inappropriate to have contra leaders
interjecting themselves into elections. It's not proper
behavior. None of them would have done it either.
Q Turning to the next page, there is an indication of
a telephone message on February 28th from Martin Artiano,
saying that he called from Jamaica to see how the meeting
with Barbara Newington went yesterday, will call back later.
Do you know why Mr. Artiano was calling you from
Jamaica to see how the Newington meeting went?
A No. I assume it was just general interest in Mrs.
Newington 's meeting.
Q Was that a meeting with President Reagan?
A I believe it was. She had two meetings with the
President.
Q You're not aware of any additional information as
to the reason for Mr. Artiano 's call?
. A I think it was just professional curiosity. He was
just keeping together with the effort.
Q On the next page, Mr. Miller, there's a phone
message from Roy Godson on December 5, which states needs
information urgently. He's leaving for Europe tomorrow.
Do you know what that refers to?
A It seems to me that this was in reference to the
Barness check. I think that's correct
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Q .. What was the information that he needed urgently?
A I think he needed to know who to have Mr. Barness
make it out to.
Q And did you convey that information to Mr. Godson?
A I don't recall whether I did or not. It may have
been that the check was simply left blank.
Q Is it your recollection that the information that
he needed urgently was unrelated to his European trip?
A ' I don't remember it being related to his European
trip. But I don't remember the specifics of this anyway. So
I can't specifically remember.
Q Do you recall ever providing any information to Mr.
Godson that was related to a trip he was making to Europe or
for him to use during an European trip?
A I don't recall. If you give me more specifics,
I'll try to, but I don't recall providing him information for
a trip to Europe.
Q Are you aware of any fund raising efforts ever
undertaken by Mr. Godson to raise money in Europe for
[related to Nicaragua?
A No.
Q Turning to page 3250, there's a phone message from
Ibrahim, I-b-r-a-h-i-m, which states he is on his way to
Frankfurt, everything is all right,. will take care of telefax
Do you recall receiving tl
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Vaguely.
Who is Ibrahim?
al-Massoudi.
Are you sure of that?
Positive.
What was the trip to Frankfurt that's referred to
A
Q
A
Q
A
Q
there?
A He was dealing with a connnodities broker in
Frankfurt' on his oil transaction, and I believe the telefax
refers to some information that I had requested he send me to
try and verify this whole transaction.
Q Turning to the next page, 3255, there is a reference
6
to a telephone message from Mr. topp of Switzerland.
Do you recall receiving that message?
A Yes, and that's the one I testified to earlier that
when he called me back, I missed the phone call, and subse-
quently got it, got another call.
C
At that time, did you know who Mr. ^opp was?
No.
Did you later learn?
Yes.
How did you learn?
I think it was in a Washington Post article in
December of this past year.
Until then you did not know the identity of Mr.
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^opp?
UNCLASSIHED
528
And, based on that, whom do you believe Mr. ^opp
A NO. In fact, you know it was the Tower Conunission
report was the first time I saw it.
Q
was?
A Ai^irai Secord.
Q Mr. Miller, directing your attention to the first
page of handwritten notes in Composite Exhibit 30, which has
your Control No. 1723, there's an item there that reads •
present him with a check, arriving late tonight, John Ramsey,
$25,000.
Is that in your handwriting?
A Yes.
Q Do you recall when you made those notes?
A Not the specific date, but sometime early spring of
1985.
Q What do those notes refer to?
A I think it's a conversation with Spitz ChannelJ^and
John Ramsey was making a $25,000 contribution.
Q And when you say present him with a check, what
does the "him" refer to?
A I can't remember which him it is, whether it's
Channell's organization or Mr. Calero.
Q And it's Ramsex utft%% tf^VflH^P? late tonight
A Yes
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Q And he's going to present the contribution of
S25,000 tonight?
A I believe that's correct.
Q Turning to page 1735, are those notes in your
handwriting?
A Yes.
Q Do you recall when you made those notes?
A I was — I can recall where I made them. I believe
it was May or June at al-Massoudi's residence in Fresno,
California.
Q May or June of 1985?
A Correct.
Q Are these notes of a conversation with al-Massoudi?
A These are all things that al-Massoudi had told me
and that I had also put a brainstorm on.
Q Now, on No. 8 appears to be a name. What is that
A Gordon Brown.
Q Who is that?
A I don't know. Somebody al-Massoudi said he knew.
Q No. 9 appears to be the name William Sullivan. Do
you know who that refers to?
A This was supposed to be the Ambassador — he
claimed that that was the U.S. Ambassador to Iran during the
revolution, and_th£t^ hf Jj^^gggf^^ationship with him.
u#rii^^iinrff
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- Q There's also a reference to Michael Ledeen in
there. Do you know why there's a reference to Michael Ledeen?
A That was my idea, to call Michael and try and see
what he knew about it .
Q How did you know Michael Ledeen?
A I met Michael as a Gulf and Caribbean scholar in
1984, I believe it was.
Q Does this page of notes refer to efforts to release
the hostages?
A Yes.
Q Why did it occur to you to contact Michael Ledeen
on that subject?
A Because what I was trying to do was get some Middle
Eastern history at the tigie" of the Islamic revolution in
Iran. And 1 had heard Michael speak about it before, and he
seemed to be knowledgeable.
Q Turning to the next page, which is page 1772, there
appears to be a reference to the situation room and Room 208.
Do you see those references at the bottom?
Yes.
Is that in your handwriting?
Yes.
What do they refer to?
Briefings . v ; . ' •: - -, :-. .-. • .; . -.-
About what? , 'i r ■• iVv'^'i >- i ' \
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A . Ceatral America, ta be given by Colonel North.
Q And was one briefing to be in the situation room
and another in Room 208?
A No. I think what happened here was that Mr.
Channeli wanted it in the situation room and it was held in
Room 208. And I think it's the same date, the 18th and the
18th.
Q And this is a group briefing for Mr. Channeli 's
contributors?
A That's correct.
Q Do you recall the date of this briefing?
A Not specifically. I thought there was more than
one in Room 208.
Q Now, there's a series of notes above those ref-
erences that are very vague, but there appears to be the word
MR. PRECUP: Is that faint?
MR. FRYMAN: Very faint, yes.
BY MR. FRYMAN:
Q There appears to be the word Facel. Do you see
that?
A Yes, but I can't tell what the rest of it says.
Oh, I know what this says. Mr. Channeli wanted to see if he
could see Chairman Fascell and his Board of Directors
MR. FRYMAN: Off the record
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(Discussion off the record.)
BY MR. FRYMANi
Q Can you tell what the rest of the notes are there?
A I just remembered that, because I have recently
seen the original piece of paper in another setting. But I
can't remember what the — I think I told him that he was too
controversial and basically that it wasn't probably a good
idea to ask.
Anyway, I didn't see no checks or hashmarks so I
didn't take any action.
Q Turning to the next page, which is 1780, is that in
your handwriting?
A Yes.
Q There's a note, Barbara Newington appointment
before July 14th, $1 million.
What is the basis for that note?
A I think this entire page is a reflection of still
outstanding assignments from Mr. Channell. And that was
something that he wanted.
g Well, what do you understand the appointment with
Barbara Newington to involve?
Was this again a reference to a meeting with
President Reagan?
I don't recall whether it was President Reagan or
Colonel North.
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Q What do you understand the reference to SI million
on that sheet to be?
A I don't have a specific recollection of what it's
tied to. Whether it was something she already gave or
whether it was something she was going to give. I don't
recall.
Q There's a further reference to a phone tapping firm
in Connecticut.
Do you know what that refers to?
A Yes . Mrs . Newington was very uncomfortable having
the Soviets in her neighborhood, and she attributed the death
of Larry McDonald to the Soviet Union in a purposeful way.
And she didn't feel very secure, and she asked Mr. Channell to
find a firm that could check her phones for taps. And Mr.
Channell asked us to do it.
Q What do you mean that she was uncomfortable with
the Soviets in her neighborhood?
Was it your understanding that there was a Soviet
residence near the residence of Mrs. Newington?
A There's something right there in her neighborhood.
I'm not quite sure what it is.
Q Did you arrange for some measures to be taken to
assure that Mrs. ^%^f>f ?^^ ' % Q|'l°Api W^jpil'S^ being tapped?
Q Turni.ng to page 3196, are those notes in your
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h£mdwritln9? . .
A Yes.
Q Now, there's a reference on that page to a spark to
Houston.
Does spark refer to Mr. Calero?
A Yes.
Q There's also a reference to Copa, C-o-p-a.
Do you know what that refers to?
A ' I believe that's an airline.
Q Do you know the name of the airline?
A No.
Q And there's a reference to|
Do you know what that is?
A I believe that's the hotel he was staying in.
Q Where was that?
A I don't remember specifically. I looks like a
lumber with six digits, but I'm not sure
of that.
Q Now, also on that page, there's a reference to
Urick, U-r-i-c-k and what appears to be Tussif, Y-u-s-s-i-f .
Do you see those references?
A Tea.
Q Do you know what those references referred to?
A They are notes from a conversation with al-Massoudi,
but beyond that l_doQ.'t have gnv specific recollections,
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Q Do they have any relationship to your involvement
on issues relating to Nicaragua?
A I don't recall. I don't remember the name Hans
Urick, and I don't have a specific recollection of that, no.
Q Would you read that section of the notes for the
record, beginning is it one Urick, U-r-i-c-k?
A That's correct.
Q And then would you just continue?
A It says, Hans Urick-Danish. No. 2 is available.
Yusiff offered by. No. 3 is 100,000 tons gas-oil.
Q Is it your recollection that those three items are
related, or do you know if they're related?
A I don't have a specific recollection about the
first item. The other two I'm sure are al-Massoudi items.
But what they mean I don't have any specific recollections.
Q Turning to the next page, and your identification
nuo^r is not clear on that page, but the page begins \272, 000
Mewington .
Is that page in your handwriting?
A Yes.
Q Do you recall making these notes?
A Yes.
Q What was the circumstances under which you made
these notes ^
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A It was a telephone conversation with Mr. Channell.
It may have been a meeting, but anyway it was a conversation
with Mr. Channell.
Q Do you recall approximately when this conversation
occurred?
A No. Sometime in '86.
Q Now, at the top, it appears to read §272,000
Newington, and then you're subtracting $40,000 for ACT ads,
leaving a balance of $232,000 with a note to send check'
immediately, and then the word Friday.
Do you know what that refers to?
A I think I'm writing down what Mr. Channell was
telling me. He told me he received a check for $272,000 from
Mrs. Newington, \40, 000 of it was for ads for the campaign
that the American Conservative Trust was sponsoring, and that
they were sending a check foirv232,000.
Q And was theY232,000 funds that were to be trans-
ferred to the account from which disbursements would be made
at the direction of Colonel North?
A It was funds to be used for — yes, yes.
Q Now, the next line states "Proof of battalion-
Larry McDonald now and January 1 through Rich within one
week . "
Do you know what that refers to?
MR. PRECUP: There are three lines, Mr. Fryman.
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I'm not sure that each — you can check with the witness
whether they're related. Nobody said they are.
BY MR. FRYMAM:
Q Fine. I mean would you just look at the next three
lines, Mr. Miller, and tell me what you understand they refer
to?
A Proof of battalion. There was a lot of talk about
the Larry McDonald Brigade. Adolf o Calero conunitted to
forming orie. And Mr. Channell was looking for proof of the
battalion. And there had been news reports about it, but no
hard ^nspEk. that they were functioning.
The now and January 1, I don't have a specific
recollection. Or through Rich within one week, I don't have
a specific recollection of either.
Q Did you understand the $232,000 was to be used for
any particular purpose?
A I don't specifically remember.
_ Q What are the notes beneath the line that says
through Rich within one week?
A The rest of it is a — part of the rest of this is
a critique by Mr. Channell of Colonel North's briefing.
Q And would you just read your notes for the record?
A We felt it was too long and not current, and that
it needed to be converted, it needed to lead off with an
explanation about the southern front — j ; j-
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Q Let me just interrupt you. •
When you say it needed to be converted, what did
you mean by that?
A Converted into what Mr. Channel 1 thought it should
be.
Q And the following notes are a description of what
he thought should be in the briefing?
A Correct .
Q Would you just continue with reading or your
paraphrase of the substance of the notes on that page?
A Southern front referred to the recent establishment
of the southern front. The parties involved was an update on
all the different entities who had joined the resistance. He
felt when he said no little girls, there were too many
children, and what was needed was a military update, and that
military update should be front by front, including discus-
sions of the sub-bases, plenty of visual effects, and a map
showing the place for the FDN^^ . And he made a point for me
to say to Colonel North that there were tigers in there —
Q What does that mean, tigers in there?
A That when Colonel North briefed his contributors,
that these people were tigers and that they much preferred
blood and guts, forget the discussion of humanitarian
assistance, and that these were arch-fconservatives .
He us
<
Texans look at
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Lyndon as an example.
Q Who was Ross Haley?
A He was a Texan that wrote "Texans Look at Lyndon."
Q Was ff^he one of the persons who attended these
briefings?
A Yes . And he recounted that Bunker Hunt had said to
him that he didn't trust Adolfo Calero, and that what he was
doing was coming out to sniff around or smell around,
whatever that meant.
Q And does that mean that Mr. Hunt had said that Mr.
Calero was coming up to smell around?
A No, no. Mr. Channell was saying that Bunker Hunt
said he did not trust Adolfo Calero, and that he was coming
up to Washington to smell around.
Q He being Mr. Hunt was coming up to smell around?
A Correct .
The rest of it is general conversation notes of Mr.
Channell, that he represented 17 millionaires, and that he
wanted Mr. McFarlane for a drink at 8 p.m.
Q When you say he represented 17 millionaires,
there's a reference to August pledges,
what does that refer to?
A I think this is in reference to one of the July
briefings. And Mr. McFarlane, he wanted Mr. McFarlane for a
drink, and that he hoped that I would convey that Mr.
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McFarlane had some- enemies and he needed to make some
friends. And he hoped to put a cap on Bert Horowitzjro anti-
Bud -- McFarlane rather.
Q Who is Bert Horowitz?
A He's a fund raiser who was supposed — well, that
Mr. Channell said was making disparaging remarks about Bud
McFarlane.
Q If you would turn to the next page, which appears
to have your Control No. 4307, is that in your handwriting?
A Yes.
Q Do you recall making those notes?
A Yes.
Q What were the circumstances where you made those
notes ?
A
Q
A
- Q
A
It was a phone conversation with Bosco Matamoros .
And do you recall the approximate time?
Mo.
Nhat does the first item in those notes refer to?
That they had captured a copy of a Cuban chemical
warfare manual, them being FDN.
Q Do you know why he was reporting this to you?
A He often reported things like that to me in phone
conversations .
Q What does the second item refer to?
A That lUnd JlellcQpters were operating in Nicaragua.
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Q What does the third item refer to? .
A That it was a unit of Sandift^ta trained combatants
who were killing people and trying to draw the blame to the
esistance fighters.
Q Now, the third item has the words weapons, ammo,
rifles, boats.
A Boots . ^ _.
Q Boots. That you believe refers to a unit of
Sandinista trained combatants?
A I'm sure of it. The M-16 machine guns, you'll
remember the Newsweek article, the combatants in the Newsweek
pictorial of the execution, supposed execution by FDN
sources, were carrying M-16s. And they had fresh boots, and
the FDN doesn't carry M-16s, never have, never will. And
that's a unit of Sandinista soldiers who dress up as contras
and go out and kill people.
Q What does the last item refer to. No. 4?
. A I think it's just a repeat of No. 1. It's a
captured manual .
Q Are pages 4244 through 4246 notes by you?
A Yes.
Q On page 4245, No. 2-A reads money in lake - make AC
understand.
What does that refer to?
A I don't want to discuss it alone. The entire next
. wa^ssifi
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three items eure referenced to the same thing, and they're all
mental notes that we had been giving an awful lot of money to
lake resources, and Adolf o Calero# seemed reluctant to
cooperate with our effort, and was inconsistent to us. And I
was trying to raise it to Colonel North so that in an attempt
to make Mr. Calero understand that we were the people giving
the money to lake resources .
Q Are these notes that you made for a meeting with
Colonel North?
A In preparation for either a meeting or a telephone
conversation.
Q And this is an outline of points you were to raise
with him?
A That I wanted to raise to him, yes. But I don't
see any slash marks or hashes so I don't know whether or not
I discussed that with hln.
Q Do you recall approximately when you made these
notes?
A
Q
A
Q
Sometime in October I guess, September.
October of —
'85.
On page 4246, No. 7-A states, "Bill Casey to weigh
in after a reference to Bunker, Garwood, Harms and Sacher
withRR." Bi^»?^!
What does that refer to?
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A - Mr. Channell wanted a meeting with the President —
for those four people together. And he wanted Bill Casey to
weigh in and Linda Chavez to weigh in.
I remember I did that in one of my notes, it meant
that it was something that I dismissed or didn't take action
on.
Q At the bottom of that page, there's a reference to
telephone logs, Prince Abdulah and Caleedf
. what does that refer to?
A I provided Colonel North with my telephone logs
from ai-Massoudi's phone calls cepcftrfrAng to- bo made to
members of a Saudi Royal Family,
^^^^^^^^^^ I have no idea
whether they did it or not.
Q The next page, 4316, does that page contain notes
by .you?
A Tes .
Q Would you explain the notes at the top portion of
the page, beginning with Barnes /Haailton?
A This was a proposal by Congressman Barnes and
Chairman Hamilton that had the backing of Congressman Fish
and Jones, I guess, to take the $14 million that the President
requested and, inAtead^ gJ-Yfi S.5_sijli$n to the International
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Red Cross ana.9 millioiv to the Contradora nations and nothing
to the Jiesistance.
Q And also on that page there's the word "Ollie" and
four items .
Would you explain what those items refer to?
A Those were things I wanted to talk to Colonel North
about. Kurt Windsor, I had heard, was associated with the
Crocker family fortune, although I don't know how. I didn't
understand what an L-1 was, and I thought maybe he would know.
Q Who had spoken to you about L-ls?
A al-Massoudi.
I'm not sure, but I think Robelo's name was Just a
reaction to President Reagan's compromise. And I don't even
know whether the nightline thing is part of it or not.
Q On page 4370, are they your notes?
A Yes.
Q WhM^d^ No. 9 refer to?
A I think that had to do with a young lady that was
stranded in Managua, NicuSftgua. And I was trying to enlist
Colonel?' lhMeg^^§^BHB[i getting her out safely. She had 4jeen
an extensive interview^p with Wesley Smith, and the Sandinista
security forces had been around to visit her family to try
and locate her afterwards . ^\^^i^% ^'If^lVi'^W ^^^ °"*'
of the country safely. LlllLAd^iti lU/
Q Is the first word in that line "paper"? /
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Uh-huh.
And what is the name in parentheses?
iC
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545
Who does
I thinJc that's my — the reasons it's in paren-
theses is I used ^^^^meaning the CIA, whoever at the CIA
Why did you use the word
was the CIA agent
would handle that.
Q
A Because I knewl
responsible for that area.
Q I don't understand how the reference to the paper
to someone at the CIA by Fawn Hall as soon as possible
relates to a girl in Managua.
A Well, there's only one group in Managua qualified
to help get somebody out «dio the American Government has an
interest in, and that's the Central Intelligence Agency.
Q And what is the paper?
. A It's just a name, address, and a description of who
the girl was.
Q And approximately when was this note?
A I don't remember specifically.
(Pause)
^^^^^^^^^was associated
■ r N. / ' s J »i J »• J ' !• r 2 « T%
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A
Q How did you know that
ffiT
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Q With whom?
A I shouldn't say telephone conversations. In
conversations with Jonathan Miller predominantly.
Q And Jonathan Miller had identified him as a CIA
employee?
A Correct .
Q Had you ever met]
A Not that I'm aware of.
Q ' Mr. Miller, turning to the page with your Control
No. 4611, beginning with that page, there are a series of
pages with your consecutive document control numbers through
your Control Ho. 4620.
Would you look at those pages?
A Yes.
Q Does each of those pages contain a reference to a
bank account?
A Tes.
Q What was your source of this bank account informa-
tion?
A Colonel North provided these to me.
Q That's with respect to each account on these pages?
A Yes. Except for your second one, which is a
recopying of the first by me. 4612 was a recopying of 4611
done by me.
Q Let's just go through these.
612 was a recopying oi to
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A I have to amend that. I'm sorry. 4614 also was
provided to me by Bosco Matamoros or Alfonso Cayallas. I've
forgotten which one.
Q Well, let's just go through these quickly one by
one.
Was the account on page 4611 provided you by
Colonel North?
A Yes, and so was that piece of paper.
Q And you know whose handwriting that is?
A No.
Q But the piece of paper was given to you by Colonel
North?
A Yes.
Q And page 4612, there's a copying by you of the
information on page 4611?
A Correct .
Q What was the source of the information on page
46413?
A That was given to m© by Colonel North.
Q Was it given to you in form? Was there a typewrit-
ten sheet or cards which is reproduced on page 4613 given to
A I believe so. i^' i! 1 VsLii ivl'^ J 3 %}r^%3
Q And you say the information on page 4614 was given
to you by someone other than Colonel North?
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A Yes. -
Q And that again was whom?
A I think it was Bosco Matamoros or Alfonso Cayallas,
but I think it was Mr. Matamoros.
Q And he gave you that piece of paper?
A No. He gave me this information and I took it down
as he read it to me.
Q So that ' s your handwriting?
A ■ Yes .
Q And 4615, what was the source of that information?
A Colonel North gave that to me and gave me the piece
of paper that it was written on.
Q And 4616'
Colonel North dictated that information to me.
Whose handwriting is that?
Mine.
At the bottom of that page, there's a reference to
75. to what appears to be N-e-i-l-l-e-s?
A Nellie.
What does that refer to?
Nellie Livingston.
And is th^t^^.directionto you from Colonel North?
Yes.
And what was the direction for you to give?
To send $75,000 to Nellie Livingston's organization.
a direction to you frc
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Q What was that organization?
Was that the Institute for Terrorism and Subnational
Conflict?
A Yes.
Q And what is the reference under that? It appears
to be five to Father something.
A Five to Father LASSI. That was to Latin American
Strategic Studies Institute run by Father Tom Dowling.
Q , And what is the note after that?
A I don't know.
Q Turning tQ,.th«^iex^ pJM^ 4617, do you know whose
handwriting appears on that page? a
A I believe that is Colonel North's handwriting.
Yes.
What does it say at the top?
account.
What did you understand this account to be?
It was ^^^^^^^M an account associated with
Q Turning to the next page, 4618, do you know where
you obtained that page?
A It was given to me by Colonel North.
Q Whose handwriting is on that page?
A Well, I||l|ifiJ%thfp:fj, jyf j'Vi'^^Qij' °i people. I think
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the line under the ID number is somebody I don't Jcnow, u. S.
is somebody I don't know. U. S. is somebody I don't know. 0.
S. is somebody I don't know. But the telex number was my
assistant, who called to get their telex number so that I had
the complete transfer information.
Q Is this —
A His handwriting is as bad as mine, so it is easily
identified.
Q .Is this one piece of paper that was given to you —
A Yes.
Q — by Colonel North?
A Yes.
Q Directing your attention to page 4619, from where
did you receive that note?
A That is a hand%/ritten note on one of my note cards
by Ad)lflfo Calero.
Q That is Mr. Calero 's writing?
A Yea .
Q And did he give you, give that note to you?
A Yes . I asked him to write down 'the bank number and
address, and he did.
Q Turning to page 4620, where did you receive that
page from?
A Colonel North gave it to mg .._ii_wss _a jtjip .of_
paper that that information was on.
ngt-i.t^ffs _a Jtrip of _
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Q Directing your attention, Mr. Miller, to the
following pages with your control numbers, 4623, 4624, and
4625, 4626 and 4627 and 4628, are those pages in your
handwriting?
A Yes.
Q Do you recall when you made these notes?
A Sometime in 1986.
Q What was the purpose of making these notes?
A .1 was trying to give Colonel North a more accurate
system to keep track of the money that was in the accounts.
Q Were these notes, were the notes on these pages all
made at approximately the same time?
A No, one of them is a more comprehensive document
than the other, and superseded the other documents.
Q Would you explain what you are referring to?
A Yes, 4623 and 4624 ware an initial attempt, but as
expenditures continued, multiple expenditures continued, for
sone of the accounts that Colonel North asked me to send
money to, I tried to keep a running total, and also to
reflect the commitments that he told me he had made, so that
his commitments didn't get out in front of his available
resources. And that is what 2645 and 2646 are. 4627 and
4628 were actually the crude beginning of that process,
starting with the $1,250,000 grant from NEPL.
Q So, tM iffiy itflwfJlf ■ flgj-fli-Qrf or the chronology of
ni^ram
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these documents, the first effort would be 4627 and 4628?
A Correct.
Q The next draft would be 4623 and 26247
A Correct.
Q And the final effort reflected in these pages would
be 4625 and 26?
A You called them drafts, I wouldn't say that' they
were efforts to keep the records on the expenditures made by
Colonel Ntorth, and the final document, 462 5 and 4626,
reflected the procedure that I chose to keep track of those
commitments .
Q Did you keep and give copies of any of these
documents to Colonel North?
A Yes, in fact, I think he received copies of all
six, and I think I made them on his Xerox machine.
Q Did you prepare them in your office?
A Yes.
Q And you took them to his office, and reviewed them
with him?
A Yes.
Q And left copies with him?
A Yes.
Q On three different occasions, I take it?
A I believe that is correct.
Q Now —
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A I am not sure whether it was three different
occasions, frankly. But, nonetheless, he received copies of
this.
Q Let's focus on the last draft, which you have
identified as Figures 4625 and 26. On the first line there
is the notation, OB Grant, do you see that?
A Yes.
Q What does that refer to?
A That's my shorthand, I use doughboys for the NEPL
principles.
Q What was the reason for using that phrase?
A Nothing in particular, just didn't want to put
their names down on a piece of paper.
Q Did you discuss with Colonel North your identifica-
tion of Mr. Channell and Mr. Conrad as doughboys?
A I probably used it in his presence, I don't know
that I discussed it with him, before I decided to start using
it._
Q Do you know if you informed Colonel North as to
what the reference to DB Grant stood for?
A Oh, I am sure I did, because I would have been
discussing this with him.
Q Now, just going down the list of commitments, there
is a reference to Neal, is -that iM^ Livingston^?
Correct .
INCUSSiFIED
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Q And ther« is a reference to LAS, what does that
refer to?
A That is LASSI, Latin American Strategic Studies
Institute. .
Q And that is Father Thomas Dttlii( ? )'l7
A
A Yes. And there is a reference to SI^^l^, what does
that refer to?
0/
A That's Ad)(lfo Calero's Organization.
Q ' And there is a reference ^C)^^^H what does that
refer to?
A That is .
Q Why did you use the phrase, ^^^1 to refer to
^^^^^^^^^^^^^^^^^^^^^^^^^and
memory jog for maintenance on living, special benefit.
Q The next reference is WJ, what does that refer to?
A Woodie Jenkins.
Q And is Hr. Jenkins' organization Friends of The
Americas?
A That's correct.
Q
A Those were the Latin American Congressmen that the
Nicaraguan Business Council brought up.
Q The next reference is to Clutch, what is th*t?
A That's Bosco Matamoros,
What is the next reference, the COTC?
to Clutch, what is that? ,
J '. 'i ^ i ;■ 'I • '
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Q And is there a second reference to Clutch, with a
date of July 24?
A Yes.
Q Now, under that there is a reference to new
commitments, and there is the initials EK, what is that?
A That's Dan Kuykendall, and that is the Gulf and
Caribbean Foundation.
Q Do you know the reason for that commitment?
A Yeah. That was their agreeing to pay the bills for
prosthesis surgery in Miami, and that was the reimbursement
to them for that.
Q And what is the reference under DK?
A UW.
Q And what is that?
A That is Uno Washington.
Q And does that refer to the Washington office of the
United Nicaraguan Opposition?
A Yes .
Q And on the next page there are the initials TZ,
what does that refer to?
A That was a final payment to Tony Zumbado for some
death benefits tiiafc JukMaa APi«f |*tfPn^° some of his camera
M&SSIFIED
Q Now, also on that page, which is 4 626, toward the
bottom, by what appears to be October, there is a number 17
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and some initials that appear to be -AGRO, do you see that?
A Yes, that is the October 17 transfer to AGRO.
Q What is that?
A That's what was listed in the AGRO Bank for POLCA
S. A., in the previous documents that you asked me about.
Q What did you understand POLCA S. A. was?
A I have no idea. I still don't know.
Q Mr. Miller, turning to page 4924 —
,MR. PRECUP: Mr. Fryman, excuse me, could we go off
the record a moment?
MR. FRYMANt Yes.
(Discussion off the record.)
MR. FRYMAN: Back on the record.
BY MR. FRYMANt
Q Directing your attention to page 4924, is that your
handwriting?
A Yes.
Q Do you recall making those notes?
A Barely.
Q Do you recall the circumstances under which you
made those notes?
A Yeah, there was some need for, I think this is the
very beginning of the heavy lifting information passed me by
Colonel North.
Q What is heavy liftj
• i
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A ■ Large payloads transported by air bo the I^esistance
/t'orces inside Nicaragua.
Q And does that note indicate that it was , that
$875,000 was needed for that purpose?
A For 800 hours of heavy drops, with L-lOOs.
Q Turning to the next page, 4925, is that your
handwriting?
A Yes.
Q Do you recall making those notes?
A Yes.
Q What was the reason you made those notes?
A These notes were given to me by Colonel North, as
to the place to send contributions
A
all aircraft. The
top half is the account data for the bank in Geneva, Switzer-
landi^ and the bottom half is a general description of the
Yes, in that money for 1^> aircraft was to be sent
aircraft that would be purchased with $60,000.
Q Hell, are the two halves of the page related? The
notes on the two halves of the page.
A
to Geneva, Switzerland, but I am not sure whether they were
both written at the same time.
Q Was that the first time Colonel North identified
the Lake Resources Account in Geneva, Switzerland to you?
A I don't recall whether it was the first time or
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Q If you would turn to the next page, which is page
4926, there are some notes on that page which appear to say
Country profile on Brunei for Dave and Martie. Do you see
those notes?
A Yes.
Q Is that in your handwriting?
A Yes.
Q What do those notes refer to?
A ' I wanted to get a country profile on Brunei to give
to Dave Fischer and Martie Artiano.
Q Why was that?
A Because I wanted to see if we could get Brunei
as a client.
Q What was the reason you thought of Brunei as a
possible client?
A Because they would be a great client.
Q Anything more than that?
A Nothing more than that.
Q What is the word under that, on the next line?
A Anthony.
Q Who does that refer to?
A Our accountants .
Q And under that? IIAIAI M f%^twawwm^
A DK.
ONCLASSIFIED'
Does that refer to Mr. Kuykendall?
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Yes.
Q Do you know why there is notes referring to your
accountants and Mr. Kuykendall, at that spot?
A Probably just that I wanted to call both of them.
Q Are those notes related to the note with respect to
a country profile on Brunei?
A No.
Q Mr. Miller, if you would look at page 4927, and
also page -4928, are those notes in your handwriting?
A Yes.
Q Do you recall making those notes?
A Yes .
Q What were the circumstances when you made those
notes, or under which you made those notes?
A They were a telephone conversation with Bosco
Matamoros, in which he was recounting a call from a — actually,
I thin^an article that was published, or about to be pub-
lished, I think in the Miami Herald, but I am not sure if I
remember.
Q And these notes relate to a summary of the allega-
tions in the article?
A Yes. It is so exact that it must have been post-
fact. In other words, it must have been already printed, and
he was reading it.
Turning to page 4963, are those notes in your
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handwriting?
A
Q
A
Q
A
Q
North?
A
Yes.
Do you see the reference $30, Ow would be neat?
Yes.
What does that refer to?
That's what Colonel North said.
Are these notes of a conversation with Colonel
Yes,
Q Was that his phrase, $30,000 would be neat?
A Yes.
Q Do you recall when this conversation occurred?
A Sometime in 1985.
Q Do the notes above that refer to information about
a specific bank account?
A Yes .
Q And was he asking you to raise a certain amount of
money?
A I don't recall whether it was raise it or transfer
it.
Q What does $50,000 at the top refer to?
A I think he was looking for $50,000.
Q But then later, he said $30,000 would be neat?
Q Yeah, but that was $30,
Tool, and it is referenced at the
-"imiFiED
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Q And was there an additional $20,000 to go to the
Indians?
A I see the note, but I don't recall it. Transfer
$20,000 to the Indians.
Q What is the number at the bottom, N0056838?
A I don't know.
Q Turning to the next page, 4970, is that your
handwriting?
A ■ No .
Q Do you know the source of this information?
A Carlos Ulvert gave this to me, I think.
Q Turning to the next page, 11002, is that your
handwriting?
A Yes .
Q What do those notes represent?
A That was an initial attempt to get some handle on
the money coming in, and expenditures by me for Colonel
North.
Q The references to contributions, and a particular
date, what do those refer to?
A NEPL contributions. I would like to point out that
that was an abortive attempt; it is not very complete.
Q That's one of your earliest attempts?
A Yes. It may well have been just an attempt from
memory, there may »yVf,l3ftV # A"tJ?gaUf JJt document, with an
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earlier date.
Q Turning to the notes which are on page 19302, is |
that your handwriting? i
A No.
Q Do you know who gave you those notes?
A Well, wait a minute, some of this is in my handwrit-
ing, yes. Yes, this is my handwriting.
Q Do you know the reason that you made those notes?
A ' Yes .
Q What was the reason?
A In December of 1985 there was a lot of confusion
about the ad campaigns that Mr. Channell had sponsored, and I
wanted to create a time line that showed the ad campaigns,
and the different organizations responsible for them, to make
it easier for members of the media^ and officials to under-
stand who was doing what, at what time. And this is a basic
piece of paper, that was my instruction to one of my employ-
ees, as to how to go about doing it.
Is the name on that page Peter blaji; ^t.^ ?
Yes.
Do you know why that name is there?
No.
Turning to page 23345, is that in your handwriting?
Yes.
What do those notes relate to?
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A I think this was the — it is two different things.
The first is a Miami International Airport Corporate Air
Center and ^ail plumber, and that was when we flew some of the
Resistance leaders up to Washington for one of Mr. Channell's
events. And then the bottom half is the information on the
backside of a telephone, for the phone company to be able to
turn on the service.
MR. FRYMAN: Off the record.
• (Discussion off the record.)
MR. FRYMAN: Back on the record.
Mr. Miller, I have no further questions, I believe
that Mr. Oliver now has some questions.
EXAMINATION BY ASSOCIATE STAFF COUNSEL OF THE HOUSE
OF REPRESENTATIVES
BY MR. OLIVER:
Q Mr. Miller, earlier in this deposition, in one of
the previous sessions, you indicated that you had worked as
oKief of News and Media Relations for AID, from February 1981
until February of 1982, is that correct?
A I think my actual title, from the very beginning,
was the Director of — I have forgotten, head of the Media
Relations Division, and then I was quickly promoted to the
Chief of n4ws and I^edia^i^lations .
Q And |ll\t service at AID was from what period to
what period?
rvice at AID was 1
LASSIFIED
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A I think it is February until February.
Q Eighty-one to '83?
A The total AID service is '81 to '83, that is
correct.
Q And when you left AID, your title was Director of
Bureau of Public Affairs?
A It was not a Bureau, it was an office, and I was
the Director of the Office of Public Affairs.
Q And what level was that in?
A It was a SES political appointment. Level 3, I
think.
Q Was it at the Deputy Assistant Secretary level?
A It was not at the Deputy Assistant Secretary level,
there was an effort by Mr. MacPherson to put it back to the
Deputy Assistant Secretary level, but it hadn't come to
fruition yet.
Q So it was just below the Assistant Secretary level?
A Again, well, first of all, AID doesn't use Assistant
Secretary, it uses Assistant Administrators, and there was an
Assistant Administrator for External Affairs, but as you are
well aware, the legislation called for an Office of Public
Affairs/ and an Office of Legislative Affairs, botftyfiy
Directors who were n^t. Presidential appointees, with^Senate
confirmation. So we were Presidential appointees, without
Senate confirmation.
UNCLASSIFIED
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Q Who was your boss?
A Peter MacPherson.
Q You reported directly in the chain of command?
A When I was Director of Public Affairs I reported
directly to Peter MacPherson, and Jay Morris, the Deputy.
Q Did you meet Frank Gomez during that period of
time?
A I did.
Q And what was his position at that time?
A When I first met Frank he was Deputy Assistant
Secretary of State for Public Affairs.
Q Did you participate in interagency groups, in which
Mr. Gomez participated?
A And that was in fact the occasion of our first
meeting, he and I together called an interagency meeting on
El Salvador, and 1 believe in February of 1982, and I sat in
on interagency meetings, and I can't recall specifically if
Mr.. Gomez was there or not.
Q What agencies participated in those meetings?
A There were a couple of different groups, there was
the Interagency Steering Committee, and I can't, off the top
of my head, remember all the people, there had to be 10
Federal agencies represented there.
And then there was a Central American Policy
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566
represented .
Q Did DOD sit on both of those interagency committees?
A I know they sat on the Interagency Committee, I
don't recall whether they sat on the Policy Committee.
Q Were representatives of the intelligence community
sitting on both of those committees?
A I was never introduced to anybody as a member of
the intelligence community.
Q 'CIA was not represented in those interagency '
committees?
A Don't ever remember seeing, they used to pass
around a sheet, and I don't ever remember seeing CIA on the
sheet.
Q Why did you decide to leave AID?
A I don't like working for the Government very much.
Q Tou have been working for the Government for two
and a half years, or something a little over two years, at
that point?
A And when I came to Washington I started as a
Federal employee, when I graduated from college, and then
left the Government in 1976, I already had tiig=«Kr a hal'f
years of Federal Service, so I am quite familiar with serving
at the bottom and the top of the Federal
didn't like either one of them, so I
Q What did you do immediately upon your resigning
iral Ga\^rnment, and I
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from AID?
A I started International Business Conununications ,
and began work on developing clients. I had a consultant's
contract with AID for some media roundtable work, and there
was one other thing in the contract, which I can't remember
off the top of my head, but it was a consultant's contract,
and it required me to provide some services to the Ad-
ministrator of the agency.
Q How long did that contract run?
A Well, it was for a year, but as I recall, it did
not run its full term, it ran, I want to say six months, but
at this stage I can't remember, but we both, Peter MacPherson
and myself, agreed that it was just, neither one of us wanted
it to continue, and so we stopped it.
Q What was the amount of the compensation for that
contract?
A I believe it was whatever the top consultant's rate
is,. «^ich is usually consistent with whatever the SES rate
is, so they are usually pretty much the same thing.
Q Did you have any other Government contracts during
that period of time, the first year, after you left AID?
A No.
Q ".^f"^" ^*!^ Ji??™^»-S*.^***^ y°" ***** * Government
contract?
USSIFIED
Well, Frank Gomez started, excuse me, the initial
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lASSIFIED
contract in February, in fact I think the contract was signecj '
February 22nd, with the State Department, in 1984. And I
don't think it was until 1985 that they were IBC contracts,
they originated as Francis D. Gomez, and then became Francis
D. Gomez International Business Communications, after we
began to form the partnership, and eventually became Inter-
national Business Communications, as Frank was a partner in
International Business Communications.
Q When Frank Gomez received the first contract, in
February of 1984, what was his relationship to you, at that
point?
A He was planning to come on board as a — attempting
to come on board as a partner, but his responsibilities at
that time were, in accounting terms, as a subcontractor.
Q A subcontractor?
A To IBC.
Q To IBC. But did the initial contract with the
Sta-te Department have your involvement, in any way?
A The initial contracts with the State Department,
our only involvement was in providing staff services and
administration, for Mr. Gomez. That would have been our
I
involvement.
Q But it was his contrpct?.
A That's correct.
Q And were you sharing offices at that time?
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A Yes. At what time?
Q At the time that he got the first State Department
contract, in February of 1984.
A Yes.
Q But you didn't have a business relationship, other
than arms-length subcontract'^contractor arrangement?
A No. I think you improperly injected the word
" arms- length. " Subcontractor doesn't mean that you are at
arms-length. It is an accounting principle. Frank Gomez was
a subcontractor to IBC, in terms of accounting. Both he and
I were working towards a full partnership, and he did
maintain some other work which he did not bring into IBC.
That is a general description of his business relationship to
me.
Q Where did you derive your income from in 1984?
A From clients.
Q Any of those clients related to Central America?
. A Tea .
Q Which ones?
A The Gulf and Caribbean Foundation, predominantly
the Gulf and Caribbean Foundation, in 1984. Well, the Gulf
and Caribbean Foundation.
Q When did that relationship begin?
A I think it was in December of 1984, maybe November.
Q Between January of 1984 and December of 1984 did
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any of your work relate to Central America?
A Yes, the Gulf and Caribbean Foundation.
Q I meant prior to, you said December of 1984, was
when you thought that Gulf and Caribbean began, and I was
asking from January of 1984 to December of '84, which is
almost a year.
A Well, I said that I believe we started working for
the Gulf and Caribbean Foundation in December or November, so
prior to gur work for the Gulf and Caribbean Foundation. our
contact with Central America would have been, in general
terms, we represented a UH agency that was involved in
funding the Third World development projects, some of which
were in Central America.
We represented, of course, I had the consulting
contract with AID, and AID is deeply involved in Central
America, and the media roundtables would have incorporated,
as it was a hot subject at the time, Central America.
_ Q I thought that you said that the consulting
contract ran from February of '83, when you left AID, for
about a year, and then you didn't-
A Correct.
Q — do the whole time. So what I am trying to do is
to fill the gap in between that contract and the Gulf and
Caribbean relationship, which I assume would be late in 1983
until late 1984, so my question is, during that period of
n't-- _^,
ICUSSIFItO
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time, after the consulting contract with AID, prior to the
Gulf and Caribbean relationship, did any of your clients
relate to Central America?
A Again, the HH agency that I just described to you,
and the others, but only in general terms. We worked with
20th Century Fox, who was doing an Olympics project, I guess
you could say that related to Central America, but only in
general terms.
Q How big a staff did you have during that period of
time?
A Two people.
Q You and one other, or you —
A Myself and two others.
Q Two others .
A Yes .
Q When did you begin to participate in the State
Department contracts, as a consultant, or when did you begin
to J)e compensated for work that yoa did in relation to the
State Department contracts.
A You asked two questions . We were trying to form a
partnership, and Mr. Gomez put his proceeds from his profes-
sional efforts into the general coffers of International
Business Communications, in an effort to develop enough
business to sustain atpartn$rstw-B«^ ^T^^ is the answer to
your second question.
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- The first question was that initially my respon-
sibility was to provide administrative and professional
backup to Mr. Gomez, and that incorporated everything from,
you know, developing media lists for his work, providing
files for development of articles.
So really, from the start, we were involved, all
the people were involved in Mr. Gomez's contract.
Q When did you first meet Otto Reich?
A I can't tell you exactly when, but it was sometime
in 1981.
Q While you were at AID?
A That's right. Otto was the Assistant Administrator
for Latin America.
Q Was Mr. Gomez's first contract with the State
Department under the office that Otto Reich headed at that
time?
A Yes.
. Q Did you have any participation or involvement at
all in securing that contract?
A I don't recall having any, no.
Q Do you know Halt Raymond?
A I have met Walt Raymond, yes.
Q When did you first meet Walt Raymond?
A I think Raymond came to some of the interagency
group meetings. I don't recall specifically which ones, but
ONCLASSIFIED
579
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I think he was present at some of them. And Prank set up a
lunch one time, I think, and maybe it was a breakfast, and I
met Raymond one time.
Q When was that?
A Sometime in 1984, I think.
Q What was the purpose of the breakfast?
A Just a get^acquainted session.
Q Do you remember what was discussed there?
A No .
Q Did you have any dealings with Walt Raymond, after
that?
A Occasionally, because in 19884 he had some involve-
ment in the information development on the Reagan Administra-
tion policy in Central America, and I am sure I have had
telephone conversations with him, or been to meetings at
which he was present.
Q Since that breakfast, and since you left the
Government?
A That's correct.
Q Do you remember what the substance of those
conversations with Walt Raymond was about, if you can
remember?
A I can't remember the substance, they would have
been generally about Central America, Reagan Administration
Central American policy, but specif icallv. I can't remember
n policy, but specifically, I can't
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any of the details.
Q Old he ever discuss fiS>h your work for Spitz?
A Mo, not that I can recall.
Q When did you — I am sorry, you said earlier that you
met Jonathan Miller in the 1980 campaign, is that correct?
A That's correct.
Q And that you became good friends?
A No.
Q ' Over a period of time?
A I didn't really get to know Jonathan until our work
together at AID.
Q And what was his job at AID?
A He was in the Legislative Affairs area for a while,
and then went to become a country Director, somewhere, I
forgot where. Assistant Country Director, I have forgotten
what position it was, but he trent off to Africa, I think. I
cail'i remember specifically.
_ Q Was that for AID, or for the Peace Corps?
A Could have been for the Peace Corps .
Q And then when did you renew your acquaintanceship?
A when he popped up again at the State Department, in
Otto Reich's office.
Q And during the time that Frank Gomez had contracts
with LPD, was Jonathan Miller the official technical represen-
tative for the _5J;p J^ Qeoartment , on those contracts, the
> _State Department , on th<
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person responsible for the oversight?
A I don't remember who was responsible in the first
contract, and that is probably because I wasn't involved in
the direct negotiations on it. But the people whom I recall
us reporting to would have been Otto Reich, Jonathan Miller,
John Blacken and John Scath.
Q You reported to all four of them?
A At different times, yes. And some of them simul-
taneously. For instance, John Blacken and Jonathan Miller
were Deputies, there were two Deputies under Otto Reich, and
then when Jonathan Miller moved, John Blacken moved up to
that Deputy slot, and I think John Scath moved into the other
one.
Q You started to report to them after IBC got its
first contract from the State Department?
A That's correct.
Q When was the first IBC contract?
.A It was signed on Febmiary, I believe the date is
correct, it was signed on February 22nd of 1984.
Q That was the Gomez contract?
A That's correct.
Q The first three contracts were in Mr. Gomez's name,
but they were with him, not with IBC. My question was when
did IBC get its first contract with the State Department?
A I am not_sur9 I 'SffT M'Saafc y""" characterization, I
tiMrR^^i^fti
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don't have a copy of the contracts in front of me. But I
believe that one or two of them said Francis D. Gomez
International Business Communications.
Q So you started to meet with these people from the
time that Frank Gomez had this contract, had his first
contract?
A I can't be that specific. I can't tell you whether
in the first three months of Frank's being at IBC whether I
met with ?ny of these people or not.
Q From October 1st of 1985 to September 30th, 1986,
IBC had a contract with the State Department that was
classified as secret, which was substantially more than
previous contracts that IBC and Frank Gomez had with the
State Department.
Could you tell me when you began to negotiate that
increased level of contract with the State Department?
A During the completion of the previous contract,
which was for 90^some thousand dollars. We were asked by
John Blacken to review the publication distribution system,
and we had given an assessment of its effectiveness. It was
a short process, and the results of our exploration were
startling to us, disheartening to us, because we had put a
lot of work into developing materials to be disseminated to
the public, only to find out that they were not getting
disseminated
(lfrif/t^i?r?iftf
istribution mechanism.
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They were very distressing to Otto Reich and John
Blacken, because that was one of their charges. And the
subsequent contract negotiations started almost immediately,
with them asking for a recommendation to have us add the
distribution process to our responsibilities of media
relations, escort services and political counseling.
So we made a proposal for Ms increased contract,
with a separate section for the distribution, and that seemed
to move quickly, until it got to the Contracts Office, who
then informed us that this was an entirely different form of
contract, that it would have to be redone, as a cost-plu^
fixed>fee contract. By this time we were already beginning
to perform the same services that we had provided in fiscal
1985, in fiscal 1986, land we were assured by the Contract
Office that they would produce a ratification letter, so that
we would not be performing these services without compensa-
tion. And %«« then irant through the process of negotiating a
coat-plus fixed^ fee contract, something that I would not wish
on anybody, it is a pretty deliberative process, including
having OCAA auditors in your offices, and full exploration of
your books, and demands for accounting practices, and so
forth.
And that all took a long period of time. In fact,
%re didn't even finish up until we were through a great
preponderance o
sioned under the
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contract.
Q So the new component, the way in which this
contract differed from the previous $90,000 contract, was the
distribution system?
A That's correct.
Q So why was it classified secret?
A Well, I can tell you why I thought it was classified
secret, and recount a conversation with Jonathan Miller to
that effect. We had drawn the interest of — we are right up
against the other barrier we were up against before — we
discussed this in a previous deposition.
I don't know, do you want to go off the record?
MR. OLIVER: Yes, let's go off the record.
(Discussion off the record.)
MR. OLIVER: Before we go any further, Mr. Miller,
do you have a security clearance from the U. S. Government at
this point?
THE WITNESS: I am not sure of that. We had one,
and we were notified by the Office of State Security, State
Department Security Office, that they were going to lift it,
so I can't tell you whether it is in force right now or not.
BY MR. OLIVER:
Q When was tt^^ la^,jtifie^^^^9^^d a personal
securi
A Up until a matter of three or four iraeks ago.
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Q You testified earlier that you had worked at, I
believe, the General Services Administration, and then the
Department of Transportation, and then AID.
A Yes.
Q During those periods of time you had Government-
authorized security clearance, isn't that correct?
A That's correct.
Q Is it your understanding that when you terminate
the employment for which the security clearances are neces-
sary, that the security clearance is also terminated?
A It is my understanding that the security clearance
is predicated on employment, so that a security clearance is
undertaken when you are employed, and you maintain your
clearance as long as you are employed, with the caveat that if
you have longer than a three^month break between employment,
then you have to go through the security clearance process
all over again.
- Q Well, between February of 1983, when you left AID,
and became a private citizen, and October 1st of 1985, what
would have been the reason for you to have a security
clearance?
A I didn't have a
Q When did you-
A Although I am 3ur« the Agency for International
Development considered my clearance active while I was a
KCTED
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consultant to Mr. MacPherson, but he would have to answer
that one.
Q Were you ever notified that you had a security
clearance, while you were a consultant?
A It isn't vacated if you have no break of employment,
is what I am trying to tell you.
Q Well, my understanding of security clearance is
considerably different. My understanding is that you have a
security Clearance, on a need^tc^know basis, for work that
you are performing for the Government, and once you stop
performing that work, you no longer have a security clearance,
and I think, all the clearances that I have had, you had to
sign papers to that effect. And I know if I leave my
employment my security clearance is no longer in effect.
And that is why I am asking you whether any steps
were taken to maintain your security clearance, after you left
the Government.
_ A No,
MR. PRECUP! By you?
THE WITNESS: By me, none were taken by me.
BY MR. OLIVER:
Q Do you know of any steps that were taken to
maintain your security clearance, while you were a consultant
to AID?
A Not that I am aware of.
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Q The contract which you were performing in the
amount of $90,000, which preceded the, I believe it ran
through September 30th, 1985?
A Correct.
Q Did that contract require a security clearance?
A No.
Q But the contract that began on October 1st, 1985
required a security clearance, is that correct?
A That is correct.
Q And it required a security clearance for how many
of your employees?
A Well, ultimately it was decided that there were
only two employees to be cleared, and that was Mr. Gomez and
myself, and that was decided finally by the Defense Investiga-
tive Agency.
Q And did they notify you that you had received
security clearances?
i^y
-u
. A They notified us that/both an interim security
clearance and the final security clearance.
Q Were those security clearances for you and Mr.
Gomez, or were those facility security clearance for your
office?
A They were, under the circumstances, actually one
and the same thing, because we were not cleared to have
classified materials, custodial responsibility for classified
HMO! ?'»«'"rn
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582
materials, and we are the facility, since it was a partner-
ship, so they decided finally it was only necessary for them
to clear the two of principal partners, which they did.
Q When did they give you an interim clearance?
A I don't remember specifically, sometime in about the
middle of the year.
MR. OLIVER: If I may, I would like to ask the
reporter to mark this as Miller Exhibit 31, and indicate that
this is a 'compilation of documents that are related to the
IBC-State Department contracts.
MR. BUCK: I was just going to suggest that the
witness look at the exhibit.
MR. PRECUP: Now, Mr. Oliver, this is a thick
document, so rather than having the witness go through it,
would you invite his attention to the specific areas.
MR. OLIVER: I will invite his attention to various
pages as vb go through, rather than ask these questions, I
will try to have him look at these documents, so he can
refresh his memory from them as we discuss them.
(The document referred to was
marked for identification as
Miller Deposition Exhibit No.
31
BY MR. OLIVER: 11^
Q If you would look at the second page of that
IHED
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compilation o£ documents, January 11th, 1985, which is a
memorandum to International Business Communications, and ask
you to identify it?
MR. PRECUP: I am not finding this.
MR. OLIVER: Page two, the next one, the very next
page.
MR. BUCK: It is just a three page document.
MR. PRECUP: To whom?
,MR. OLIVER: It is a January 11, 1985 memorandum/
MR. PRECUP: We found it.
BY MR. OLIVER:
Q I would like to ask you to examine that document,
and tell me whether or not you have ever seen it before.
A Yes.
Q Is this document an accurate reflection of the
services that Frank Gomez and IBC performed for the State
Department on the $90,000 contract that ran from, I believe
it ran fiscal 1985?
A No, actually I think this is fiscal, no, you are
right, it is the first quarter of fiscal year 1985.
Q Actually, it looks like the last quarter of fiscal
1984 and the first three months of 1965, but let me rephrase
the question.
Is this an accurate reflection of the work that IBC
was doing for the State Department in January of 1985, had
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584
been performing, for the State Department? .-.. ....... .
A Yes.
Q Were you involved in any or all of these 10 items?
A Many of these 10 items.
Q Was anyone else, besides you and Mr. Gomez,
involved in work for IBC, involved in these activities?
A Sure.
Q Who were the others who had responsibilities for
any of th^se specific items?
A Jeff Keffer, Jacqueline Clemonds, Mona St. Leger, I
am going to embarrass my employees when I don't remember all
their names, Anna Chrysler, and some subcontractors, as well.
Q Number 2 on that list, says Creation and Implementa-
tion of Immediate Plans for S/LPD-directed newsmakers, what
does that mean?
A There were people who S/LPD brought up to Washing-
ton, to have them address the media on Central American
issues. People like defectors, atrocity victims, refugees.
Q When you say LPD brought them up, what do you mean,
do you mean they paid for them?
A I can't tell you who paid to get them here, but
once they got here they were S/LPD' s responsibility.
Q Do you know who paid their expenses?
A Not specifically,, no. We would sometimes get
organizations to sponsor them^ and have those organizations
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58S
pick up thalr expenses . But that was Washington expenses , or
U. S. expenses. But how they got to the United States^se
"nisr, I can't tell you who paid for it.
Q What made you think that S/LPD brought them up?
A Well, I will use a different phrase. I was aware
that when they got here they were S/LPD' s responsibility.
Obviously S/LPD would have had some coordination in getting
them here, or they wouldn't have been able to notify us that
they were coming.
Q So you were asked by LPD to create and implement
media plans for these people?
A That's correct.
Q And did that include appearances on television, and
press conferences, interviews with newspapers?
A That's correct.
Q Did it include appointments with Government
officials?
A Some of their schedules included Government
officials, but those appointments were not generally set by
us. In fact, they were rarely set by us.
Q Who set them?
A Somebody in S/LPD. There was normally an official
in S/LPD who had responsibility for these people. We also
ion to make
some contacts foi
sometimes depended on the sponso^igo
ed on the sponsojiM^cai
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Q Number 3 says writing, editing and distribution
plans for ^^^c and news articles for S/LPD officials, and
S/LPD-designated newsmakers. Who were the S/LPD officials
that you refer to in that?
A John Blacken, Jonathan Miller, Otto Reich, anybody
who would sign an (UIVCB^ or letter to the editor.
A
Q So you would write them, and edit them, and they
would sign them, and then you would distribute them to
newspapers?
A No, we would write them, and edit them, and then
give them a distribution plan, and they would distribute
them.
Q What are S/LPD-designated newsmakers?
A There were a lot of people within the State
Department, and Defense Department who were participants in
5,
the S/LPD ne«naking process.
Q Do you remember who some of those people were?
A Not off the top of my head.
Q Number 10 says "Served as liaison with groups
active in promoting democracy through programs in Central
America and the United States . " Which groups were you the
liaison with promoting democracy in the United States?
A Well, I guess you can read that sentence that way,
but we were not engaged in the business of promoting democracy
in the United Statas^ We were engaged in the business of
tas^ We were engaged in
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_ 1 il promoting Central American democracy, and we did that
2 I sometimes in the United States.
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Q Do you remember some of the groups that you served
as liaison with?
A Yes, PRODEMCA, Gulf and Caribbean Foundation,
Freedom House,' I am tired, and those are the only ones I can
remember off the top of my head.
Q So those were —
A .Institute for Religion and Democracy, Catholic
Church, The Evangelical Association.
Q So your interaction with those groups, from
September of 1984 to January of 1985, was part of your
responsibilities, under your State Department contract, is
that correct?
A We were sometimes asked by officials of S/LPD to
represent them in n^eetings, or such organizations. But it
didn't account for all of our contact with those organiza-
tions.
Q In the summary, at the bottom of the page, it said
that "The above activities were carried at the direction of
S/LPD." So is it safe to assume that all of the things that
are listed there were done at t,heir-dijecij^n?
A Yes.
uL
'fi
Q You indicated a minute ago, when I asked you who
performed these things, you listed a number of people, and
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you also said .several subcontractors.
A Yes, I misspoke. He didn't use subcontractors
until our 1986 contract, although we may have used them after
this contract.
Q After that date?
A Well, after December, there may have been some
subcontractor use.
Q Was there another report submitted to the State
Department on your activities, other than this piece of paper?
A Oh, sure. There were several reports. In fact —
Q I am talking about for this period of time, from
September of 1984 until January of 1985.
A I will say that there were many reports submitted.
Off the top of my head I can't tell you whether any fell in
that three> month period or not. And I believe the staff has
been provided with an entire notebook full of those reports.
Q When did you begin work on your fiscal year 1986
contract that was designated as secret?
A The first day of fiscal year 1986.
Q How could you perform the secret contract, if you
didn't have a security clearance?
A I don't think it had been stamped secret at that
point in time.
Q Well, how did you know what you were supposed to be
doing, if you didn't have the contract? g gij^ a i O '^ -> t .- -•
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A We were doing exactly what we had done the year
2 1 before, with the addition of the distribution activities.
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Q But what you had done the year before did not
require a secret clearance?
A No.
Q So was it the distribution system that required a
secret clearance?
A No.
Q .Why did you need a facility clearance for your
offices?
A We didn't, and I don't think we ultimately got one.
We ultimately got a clearance for the two principal members
of the firm, I think that is the way they finally did it.
Q Let's look at the contract.
MR. OLIVER: If you would look at, about half-way
through this packet, at a letter from the Defense Investiga-
tive Service. The bottom of it has a designation, j-2.
MR. PRECUP: We have it.
BY MR. OLIVER!
Q That is a letter to the Chief of the Procedures
Security Division, Department of State, from the Defense
Investigative Service, indicating that the facility was
granting- an interim "secret" security clearance on July 30th,
1986. It doesn't have the capability to safeguard classified
material .
BNCUSSIHHL
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Prior to July 30th of 1986 when you received this
interim "secret" for the facility, but without storage
capacity for classified material, had you ever been given any
notification that you/ or Mr. Gomez had received individual
security clearances?
A No. I don't think so.
Q Were you ever notified that you/ or Mr. Gomez,
during the period of this contract, had received security
clearances?
A No.
Q When you signed this contract on September the 2nd,
1986, did you have a "secret" security clearance?
A No.
Q How could you read the contract if you didn't have
a clearance?
MR. PRECUP: I think that's a rhetorical question.
THE WITNESS: I'm not sure I read the contract —
MR. OLIVER: Well, I mean, it's a serious question,
and it's one that's been raised by a number of people, is how
could somebody without a "secret" clearance read a "secret"
document .
BY MR. OLIVER:
Q Was there any discussion^f^ that when you signed
this contract?
A Yes. I was given it by the contracts officer to
there any discussion of t
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sign and then she took back the contract.
Q But you did not have a copy of it?
A I did not have a copy of it.
Q Was it stamped 'secret" at the time you signed it?
A I think so, but I'm not sure.
Q So you did not have a copy of the contract at any
time during the period 
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